Title
Supreme Court
Spouses Mangaron vs. Hanna Via Design and Construction
Case
G.R. No. 224186
Decision Date
Sep 23, 2019
Spouses sued for damages after a vehicular accident, alleging vicarious liability. SC upheld CA, ruling respondent not liable under registered owner rule; liability lies with vehicle's registered owner, Power Supply.

Case Digest (G.R. No. 224186)
Expanded Legal Reasoning Model

Facts:

  • Parties and Complaint
    • Spouses Emilio Mangaron, Jr. and Erlinda Mangaron (petitioners) filed a complaint for damages against Hanna Via Design and Construction - Deepwell Drilling Division (respondent), Power Supply and Equipment Parts (Power Supply), and their company driver, Crestino T. Bosquit (Bosquit).
    • The complaint was filed under Article 2184 of the Civil Code in relation to Article 2180, alleging vicarious liability of the respondent due to the negligent driving of Bosquit.
    • The incident involved an Isuzu truck with Plate Number PLM 612 (subject vehicle) owned by Power Supply that bumped and dragged petitioners' Ford Ranger Pick-Up with Plate Number XJZ-830, causing serious physical injuries.
    • Petitioners were hospitalized for a full month at Davao Doctors Hospital due to the injuries sustained.
  • Trial Court Proceedings
    • After petitioners rested their case, the respondent filed a Motion for Demurrer to Evidence.
    • Respondent challenged the RTC’s jurisdiction, asserting the complaint was criminal in nature (reckless imprudence resulting in physical injuries) and should have been filed in Davao City where the incident occurred.
    • The RTC of Malolos City, Branch 11, denied the motion on May 20, 2014, ruling that issues raised were matters of evidence and that the case was civil in nature.
    • Respondent’s Motion for Reconsideration was denied on September 26, 2014.
  • Court of Appeals Proceedings
    • Respondent filed a Petition for Certiorari with the CA to challenge the RTC’s jurisdiction denial.
    • On October 20, 2015, the CA upheld the RTC’s jurisdiction but reversed the denial of the demurrer to evidence, finding grave abuse of discretion by the RTC.
    • The CA held that Power Supply, as the registered owner of the subject vehicle, was primarily liable, not Hanna Via Design and Construction.
    • Petitioners filed a Motion for Reconsideration, which the CA denied on April 14, 2016.
  • Petition to the Supreme Court
    • Petitioners assailed the CA ruling for:
      • Giving due course to the certiorari petition despite the denial of motion for demurrer being interlocutory;
      • Setting aside the RTC’s order despite alleged sufficient basis for its denial.

Issues:

  • Whether the denial of the motion for demurrer to evidence by the RTC was proper.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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