Case Digest (G.R. No. L-38346-47) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Spouses Benjamin C. Mamaril and Sonia P. Mamaril vs. The Boy Scout of the Philippines, AIB Security Agency, Inc., Cesario PeAa and Vicente Gaddi (G.R. No. 179382, January 14, 2013), petitioners (“Sps. Mamaril”) have been operating six-passenger jeepneys since 1971 and paid P300.00 per month per unit to park inside the Boy Scout of the Philippines (“BSP”) compound in Malate, Manila. On the evening of May 26, 1995, all jeepneys were duly parked but the following morning one jeepney (Plate No. DCG 392) went missing. The security guards on duty, Cesario PeAa and Vicente Gaddi, employed by AIB Security Agency, Inc. (“AIB”) under a Guard Service Contract with BSP, admitted that they allowed a familiar-looking stranger to drive the jeepney out. On November 20, 1996, Sps. Mamaril filed suit before the Regional Trial Court (RTC) of Manila, Branch 39, for damages against BSP, AIB, PeAa and Gaddi, claiming (a) the value of the lost vehicle and accessories (P300,000.00), (b) daily loss o Case Digest (G.R. No. L-38346-47) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- Spouses Benjamin C. Mamaril and Sonia P. Mamaril (Sps. Mamaril) have operated six-passenger jeepneys since 1971 and parked them nightly at the Boy Scouts of the Philippines (BSP) compound in Malate, Manila, at ₱300.00 per unit per month.
- On May 26, 1995, their jeepneys were parked inside the BSP premises; the next morning, the vehicle bearing Plate No. DCG 392 was missing and never recovered.
- BSP had contracted AIB Security Agency, Inc. (AIB) to provide security; its guards, Cesario Peñaa and Vicente Gaddi, admitted during investigation that they negligently allowed an acquaintance of the owners to drive out the jeepney.
- Procedural History
- November 20, 1996: Sps. Mamaril filed Civil Case No. 96-80950 before the Regional Trial Court (RTC) Manila, Branch 39, against BSP, AIB, Peñaa, and Gaddi, seeking:
- Value of jeepney and accessories (₱300,000.00).
- Daily income loss (₱275.00/day).
- Exemplary and moral damages.
- Attorney’s fees and costs of suit.
- Defenses:
- BSP invoked exculpatory clause on its parking ticket and argued the Guard Service Contract covered only BSP’s own property, officers, and employees.
- AIB claimed due diligence in guard selection and supervision; the guards contended the driver appeared authorized and had a key.
- November 28, 2001 RTC Decision: Held BSP, AIB, Peñaa, and Gaddi jointly and severally liable to pay:
- Cost of jeepney (₱250,000.00) and accessories (₱50,000.00).
- Income loss (₱275.00/day).
- Moral damages (₱50,000.00) and exemplary damages (₱50,000.00).
- Attorney’s fees (₱50,000.00) and ₱1,500.00 per court appearance.
- Costs of suit.
- June 11, 2002 RTC Modification: Reduced vehicle value award to ₱200,000.00.
- BSP alone appealed to the Court of Appeals (CA).
- CA Decision and Supreme Court Petition
- May 31, 2007 CA Decision (CA-G.R. CV No. 75978):
- Affirmed guards’ negligence; held only AIB, Peñaa, and Gaddi jointly liable (₱200,000.00).
- Deleted awards for accessories, income loss, moral and exemplary damages, and attorney’s fees due to lack of proof.
- Absolved BSP from any liability.
- August 16, 2007 CA Resolution: Denied Sps. Mamaril’s motion for reconsideration.
- Sps. Mamaril filed a Petition for Review on Certiorari before the Supreme Court, assigning four errors concerning BSP’s liability, contract interpretation, lease characterization, and deletion of damages and attorney’s fees.
Issues:
- Whether the CA erred in absolving BSP from any liability for the loss of the jeepney.
- Whether the Guard Service Contract between BSP and AIB created obligations in favor of third parties such as Sps. Mamaril.
- Whether the CA wrongly classified the parking arrangement as a lease, thereby relieving BSP of a duty to protect the vehicles.
- Whether the deletion of awards for accessories, income loss, moral and exemplary damages, and attorney’s fees was in error.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)