Case Summary (G.R. No. 211212)
Key Dates
- July 13, 2000: Accident on Sampaguita Street, Parañaque City; Reyes hit by petitioner’s van
- July 31, 2003: RTC Decision finding gross negligence and awarding damages
- October 20, 2003: RTC Order denying petitioner’s motion for reconsideration
- October 3, 2005: CA Decision affirming RTC with modifications
- November 29, 2005: CA Resolution denying reconsideration
- February 10, 2016: SC Decision
Applicable Law
- 1987 Philippine Constitution
- Civil Code: Articles 2176 (quasi-delict), 2180 (vicarious liability of employers), 2206 (minimum indemnity for death), 2231 (exemplary damages for gross negligence)
- Family Code: Articles 216, 220, 233 (substitute parental authority and its extent)
- Land Transportation and Traffic Code, Sec. 24 (professional driver’s license requirement)
Factual Background
On July 13, 2000, Reyes was struck by a Mitsubishi L-300 van driven by petitioner’s employee Bautista. Witnesses observed gross negligence: instead of taking her to a hospital, Bautista left her inside the parked van. The van was registered in the name of Caravan. Reyes was later brought to a hospital by a civilian but died two days later. Respondent, as Reyes’ substitute parent, shouldered hospitalization expenses and subsequently filed a complaint for damages against Bautista and Caravan.
Procedural History
- RTC (Branch 258, Parañaque City) granted respondent’s motion to drop Bautista for lack of service, found Bautista grossly negligent, and ordered joint and solidary payment by Bautista and Caravan of actual, moral, exemplary damages, attorney’s fees, and costs.
- RTC denied Caravan’s motion for reconsideration (Oct. 20, 2003).
- CA affirmed with modifications: reduced moral damages, awarded death indemnity, adjusted interest rates, and imposed costs on Caravan.
- CA denied reconsideration (Nov. 29, 2005).
- Caravan filed petition for review on certiorari before the SC.
Issues
- Whether respondent is a real party in interest entitled to sue for Reyes’ death.
- Whether petitioner is liable as employer under Article 2180 of the Civil Code.
Real Party in Interest
- Rule 3, Sec. 2, 1997 Rules of Civil Procedure: a real party in interest stands to benefit or be harmed by the judgment.
- Respondent exercised substitute parental authority (Family Code, Arts. 216, 233) over Reyes, supported her until emancipation at 18, and incurred funeral and medical expenses.
- She suffered actual personal loss and possesses the capacities of a parent to enforce quasi-delict claims.
- Conclusion: respondent is properly before the court as a real party in interest.
Employer’s Vicarious Liability (Article 2180)
- Employer liability for acts of employees acting within the scope of assigned tasks, unless employer proves due diligence in selection/supervision (Civil Code, Art. 2180).
- To establish liability: (1) prove employer–employee relationship; (2) show driver acted within scope; (3) negate employer’s defense of due diligence.
Registered-Owner Rule and Harmonization
- Jurisprudence (Erezo v. Jepte; Aguilar, Sr.; Del Carmen; Filcar; Mendoza) holds that a vehicle’s registered owner is primarily liable for injuries caused by its use on public highways.
- Harmonizing Civil Code Arts. 2176–2180 with the registered-owner rule: once ownership of vehicle is established by registration, a rebuttable presumption arises that employer-driver liability requirements are met.
- Burden shifts to registered owner to prove: no employment relationship, driver acted outside scope, or exercise of due diligence in selection/supervision.
Application to Caravan Travel and Tours
- Respondent introduced the Certificate of Registration to prove ownership; petitioner did not dispute it.
- Presumption arose that Bautista acted within scope and that petitioner failed to exercise due diligence.
- Petitioner’s accountant witness disclaimed knowledge of Bautista’s assignment at accident time. No proof driver was off-duty or in private capacity.
- Petitioner violated LTT Code Sec. 24 by employing Bautista with only a non-professional license.
- Company memoranda and rules were not shown to have been actually implemented or monitored (Metro Manila Transit doctrine).
- Conclusion: petitioner failed to rebut presumption; liability under Art. 2180 attaches.
Damages and Interest
- Actual damages (P35,000 funeral
Case Syllabus (G.R. No. 211212)
Procedural History
- Abejar filed a complaint for damages before the RTC of Parañaque against Bautista and Caravan for Reyes’s death by vehicular mishap.
- Bautista was unserved and subsequently dropped as a defendant; Caravan remained.
- The RTC found Bautista grossly negligent, held Caravan solidarily liable, and awarded actual, moral, exemplary damages, attorney’s fees, and costs.
- Caravan’s motion for reconsideration in the RTC was denied (Oct. 20, 2003).
- The Court of Appeals affirmed with modification (Oct. 3, 2005): reduced moral damages, added death indemnity, adjusted interest rates, and taxed costs against Caravan.
- Caravan’s motion for reconsideration in the CA was denied (Nov. 29, 2005); Caravan then filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court.
Facts
- On July 13, 2000, Reyes was walking on Sampaguita Street, Parañaque City, when a Mitsubishi L-300 van (plate PKM 195) swerved and struck her.
- Witness Espinosa loaded injured Reyes into the van; driver Bautista parked inside a subdivision with Reyes unattended; a civilian later brought her to the hospital.
- Caravan was the registered owner of the van; Bautista was Caravan’s service driver; Caravan paid Reyes’s hospitalization.
- Reyes died two days later; Abejar, her paternal aunt and de facto custodian since age 9, suffered loss and filed suit.
- Caravan claimed Abejar lacked personality to sue, that Bautista acted outside scope, and that it had exercised due diligence; it also challenged the award of various damages.
Issues
- Is Ermilinda Ab