Title
Imperial vs. Heirs of Spouses Bayaban
Case
G.R. No. 197626
Decision Date
Oct 3, 2018
A collision involving a van and tricycle caused severe injuries to spouses Bayaban. The van owner, Imperial, was held vicariously liable for his driver’s negligence, failing to prove due diligence. The Supreme Court affirmed damages, including actual, moral, exemplary, and temperate damages, with legal interest.
negligence
employer negligence
solidary liability

Case Summary (G.R. No. 197626)

Factual Background

On December 14, 2003, at about 3:00 p.m., a collision occurred along Sumulong Highway, Antipolo City, involving a Mitsubishi L-300 van registered to Raul S. Imperial and driven by his driver, William Laraga, and a tricycle driven by Gerardo Mercado. On board the tricycle were respondents Neil and Mary Lou Bayaban, who sustained multiple fractures and serious injuries, were treated at Unciano Hospital, and later underwent therapy and post-medical treatment. The Bayaban Spouses demanded compensation from Imperial, Laraga, and Mercado; when the demand was not complied with, they filed a complaint for damages before the Regional Trial Court, impleading Imperial, Laraga, and Mercado as defendants.

Trial Court Proceedings

The Regional Trial Court, after trial, found William Laraga negligent and the proximate cause of the accident by attempting to overtake another vehicle and colliding with the tricycle. The court held Raul S. Imperial liable as the registered owner and employer because Imperial failed to prove that he exercised due diligence in the selection and supervision of Laraga. The trial court admitted original official receipts for medical and hospital expenses and awarded respondents actual damages for medical expenses, P100,000.00 for lost earnings during medical treatment, moral damages of P50,000.00, exemplary damages of P50,000.00, attorney’s fees of P25,000.00, and costs of suit, with the defendants ordered to pay jointly and severally.

Court of Appeals Ruling

On appeal, the Court of Appeals affirmed the trial court’s finding of liability against Raul S. Imperial and William Laraga, reiterating the principle that the registered owner of a motor vehicle is primarily and directly responsible for the consequences of its operation, including the negligence of the driver. The Court of Appeals rejected Imperial’s contentions that the van was in the custody of a third person or that Laraga was on his day off, noting lack of proof and absence of testimony from Laraga or the alleged custodian. The appellate court modified the award by deleting the P100,000.00 temperate damages for lost earnings during medical treatment on the ground that the claim was not substantiated and that temperate and actual damages were mutually exclusive.

Issues on Review

This Court framed the issues as whether the Court of Appeals improperly shifted the burden to Raul S. Imperial to prove that William Laraga was not acting within the scope of his assigned tasks, and whether the original official receipts for medical and hospital bills were incompetent evidence because they were not authenticated under Rule 132, Section 20 of the Rules of Court.

Petitioner's Contentions

Petitioner Raul S. Imperial argued, relying on Castilex Industrial Corporation v. Vasquez, Jr., that respondents failed to prove that Laraga was acting within the scope of his assigned tasks at the time of the accident; thus the plaintiff bore the burden of proof. Imperial further contended that the original official receipts, though genuine, were not authenticated as required under Rule 132, Section 20, and therefore were not competent evidence of actual damages.

Respondents' Contentions

Respondents contended that Imperial admitted that Laraga was his family stay-in driver and that, even though the accident occurred on a Sunday, it was reasonable to infer that Laraga was being utilized as a driver in furtherance of Imperial’s interests, especially given Imperial’s own allegation that the van was loaned for maintenance of his greenhouse. Respondents further argued that Imperial failed to prove due diligence in selection and supervision of Laraga because he produced no documentary proof of Laraga’s formal driving lessons and that the original hospital and medical receipts issued to Mary Lou and Neil Bayaban were competent evidence, authenticated by Mary Lou’s testimony.

Applicable Law

This Court reiterated that Article 2176 defines quasi-delict and that Article 2180 imposes vicarious liability upon employers for damages caused by employees acting within the scope of their assigned tasks, while permitting employers to escape liability by proving that they observed the diligence of a good father of a family. The Court recalled the rule that the plaintiff bears the burden of proving the employer-employee relationship and that the employee was acting within the scope of assigned tasks, under the maxim ei incumbit probatio qui dicit, non qui negat. Once those facts are shown, the presumption of employer negligence in selection and supervision arises and is disputable by evidence that the employer exercised due diligence.

Supreme Court’s Analysis on Vicarious Liability

Applying the foregoing principles, the Court found that respondents discharged the initial burden of proof. Imperial admitted that Laraga was his driver. The circumstances established that Laraga was operating the van in Antipolo at about 3:00 p.m., and Imperial himself alleged the van had been loaned for maintenance of his greenhouse and water pipes in Antipolo, supporting the inference that Laraga was driving in furtherance of Imperial’s interests. Imperial’s claim that Laraga was on a day off lacked proof and Laraga did not testify. With respondents having proved that Laraga was acting within his assigned tasks, the disputable presumption that Imperial was negligent in selection and supervision arose. The Court held that Imperial failed to rebut that presumption: he offered self-serving testimony but produced no documentary evidence that he had enrolled Laraga in formal driving lessons or otherwise exercised the diligence required by Article 2180. The Court therefore affirmed that Imperial was solidarily liable with Laraga for the quasi-delict.

Supreme Court’s Analysis on Proof of Medical Receipts

The Court addressed petitioner’s contention that the original official receipts were inadmissible for lack of authentication. It explained that hospital and medical receipts are private documents not enumerated in Rule 132, Section 19, and thus ordinarily require authentication under Rule 132, Section 20 either by a witness who saw the document executed or by proof of genuineness of the signature. The Court found that respondent Mary Lou Bayaban testified to the circumstances of the accident and to the payments upon which the receipts were issued to her and Neil. Her testimony constituted competent evidence that the receipts were issued to and for the respondents, thereby satisfying the authentication requirement. Because the receipts were original, they were the best evidence of their contents for proving actual medical and hospital expenses. The trial court therefore correctly admitted them in evidence.

Damages

The Court affirmed the award of P462,868.83 as actual damages representing medical expenses, moral damages of P50,000.00, exemplary damages of P50,000.00, attor

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