Case Summary (G.R. No. 9734)

Presumption of Employer Negligence

• Under Article 1903 of the Civil Code, if an injury results from the negligence of an employee, there is a legal presumption of negligence on the part of the employer.
• This presumption arises from either the employer's failure in selecting the employee or in supervising them after selection, or both.
• The presumption is rebuttable, meaning the employer can present evidence to counter this presumption.

Rebuttal of Presumption

• The employer can overcome the presumption of negligence by demonstrating that they exercised the care and diligence of a "good father of a family" in both the selection and supervision of the employee.
• This standard requires the employer to show that they took reasonable steps to ensure the safety and competence of their employees.

Scope of Supervision

• Supervision by the employer includes the establishment of appropriate rules and regulations, as well as providing suitable instructions for employees.
• These measures are intended to protect individuals who may be affected by the actions of the employees.

Liability in Temporary Engagements

• A person who temporarily engages an automobile, along with a driver and mechanic, from a reputable garage is not automatically liable for accidents caused by the vehicle.
• If the vehicle is in apparent good condition and the driver and mechanic are experienced and licensed, the employer is not liable for accidents resulting from defects unknown to them.

Case Background and Judgment

• The case involves an appeal regarding the death of a child caused by an automobile accident, with the plaintiff seeking damages from the defendants.
• The automobile was owned by Fausta Litonjua but was managed and rented out by her son, Ramon Ramirez, who operated the garage.
• The accident occurred due to a defect in the steering gear, which neither the employer nor the employees were aware of.

Dismissal of Claims Against Fausta Litonjua

• The court found that Fausta Litonjua, while the owner of the automobile, was not liable for the accident as she had no control over the garage's operations or the rental agreement.
• The judgment against her was affirmed, indicating that ownership alone does not confer liability in this context.

Reversal of Judgment Against Mariano Leynes

• The court determined that Mariano Leynes, although the automobile was under his direction, had exercised due diligence in selecting the vehicle and its operators.
• Le...continue reading

Case Syllabus (G.R. No. 9734)

Case Overview

• This case concerns an appeal by Mariano Leynes from a judgment by the Court of First Instance of Manila, which ordered him to pay the plaintiff, Juan Bahia, the sum of P1,000 in damages.
• The plaintiff also appealed the dismissal of his complaint against Fausta Litonjua, who is the mother of Ramon Ramirez, the owner of the automobile involved in the incident.
• The action seeks to recover damages for the death of Bahia's daughter, allegedly caused by the negligence of the defendants' servant while driving the automobile.

Factual Background

• Ramon Ramirez owned and managed the International Garage in Manila.
• Fausta Litonjua, Ramirez's mother, purchased an automobile and entrusted it to her son's garage for business purposes.
• On May 14, 1911, Ramirez rented the automobile to Mariano Leynes, along with a chauffeur and a machinist, for a fiesta transport service between Balayan and Tuy, Batangas.
• On May 16, 1911, the automobile malfunctioned due to a defect in its steering gear, resulting in a catastrophic accident that led to the death of the plaintiff's daughter.

Legal Proceedings

• The case was initiated against both Fausta Litonjua and Mariano Leynes, while Ramirez was not included as a party in the lawsuit.
• The trial co...continue reading