G.R. No. 187104 - Saint Louis University, Inc. vs. Cobarrubias

Respondent Priscilla R. Domingo was the registered owner of a silver Mitsubishi Lancer, model 1980, plate No. NDW 781 a91.
Leandro Luis R. Domingo, co-respondent, was the authorized driver of the said vehicle.
Petitioner Nostradamus Villanueva was the registered owner of a green Mitsubishi Lancer, plate No. PHK 201 a91, which he claimed to have swapped for a Pajero owned by Albert Jaucian/Auto Palace Car Exchange prior to the accident.

On October 22, 1991, at about 9:45 PM, Priscilla Domingo’s silver Lancer was cruising along South Superhighway, following a green light.
Renato Dela Cruz Ocfemia drove the green Mitsubishi Lancer (plate PHK 201 a91) and suddenly darted from Vito Cruz Street into the vehicle’s path, colliding and bumping the left front portion of NDW 781 a91.
The impact caused the silver Lancer to hit two parked vehicles, one of which hit another parked car.
Traffic Accident Report revealed that Ocfemia was driving with an expired license and had alcohol on his breath.
Manila Assistant City Prosecutor recommended filing charges for reckless imprudence resulting in damage to property and injuries.

The complaint was amended to implead Auto Palace Car Exchange and Albert Jaucian as principal defendant under its name.
Petitioner Villanueva claimed non-liability since he was not the owner at the time of the accident, having already swapped the vehicle with Jaucian.
Linda Gonzales testified she was present as agent/seller for Jaucian, the actual owner of the green Lancer.
Auto Palace Car Exchange, through Jaucian, denied ownership and subsidiary liability, contending Ocfemia was off-duty as an employee at the time of the accident and not acting within employment scope.

The trial court found petitioner Villanueva liable for actual, moral, and exemplary damages, attorney’s fees, and appearance fees totaling P 99,580 actual damages, P 25,000 moral, P 25,000 exemplary, P 10,000 attorney’s fees, and P 500 per hearing appearance fees.
The Court of Appeals affirmed the liability and award except for deleting attorney’s and appearance fees due to lack of justification in the decision body.

Whether the registered owner of a motor vehicle can be held liable for damages arising from a vehicular accident involving the vehicle operated by an employee of its buyer without the latter’s consent and knowledge.