G.R. No. 182705 - Josefa vs. Manila Electric Co.

Case Summary (G.R. No. 182705)

Factual Background

On April 21, 1991, a vehicular accident involving a dump truck (registered to Josefa), a jeepney, and a car resulted in damage to a 45-foot wooden electricity post, transformers, and electrical line attachments belonging to Meralco. Investigation showed the truck hit the post, prompting Meralco to demand reimbursement, which Josefa refused, leading to a lawsuit filed on September 28, 1993.

Trial Court Proceedings and Evidence

Meralco’s complaint imputed primary liability to Josefa for the negligence of Bautista, the truck driver, seeking actual damages, attorney’s fees, litigation expenses, and costs. Josefa denied the employment relationship with Bautista and claimed diligence in employee supervision, even filing a counterclaim accusing Meralco's complaint of being baseless. Meralco presented testimony from six witnesses, including investigators, the jeepney driver eyewitness, police officers, Meralco’s foreman, and accountant, alongside documentary evidence for actual damages. Josefa's demurrer to evidence was denied; however, he later waived the presentation of evidence. The RTC dismissed the complaint due to insufficient evidence, particularly doubting the credibility of hearsay testimony and lacking proof of damages.

Court of Appeals’ Decision

The CA reversed the RTC, holding that the parties agreed the truck hit the electricity post and that Bautista was an employee of Josefa. It applied vicarious liability per Article 2180, paragraph 5 of the Civil Code, holding Josefa liable for damages caused by Bautista within the scope of his employment. The CA found Josefa failed to rebut the presumption of negligence due to non-presentation of evidence. It also ruled that even without an employer-employee relationship, Josefa would be responsible as the registered vehicle owner presumed to control the truck. The CA awarded Meralco actual damages, attorney’s fees, litigation expenses, and doubled costs.

Issues Presented

Whether the truck with plate PAK-874 hit the electricity post.
Whether Bautista exercised due diligence in driving the truck at the time of the accident.
Whether Josefa is vicariously liable for Bautista’s negligence, considering:
a. Existence of employer-employee relationship.
b. Whether Josefa exercised proper diligence in selecting and supervising Bautista.
Entitlement of Meralco to actual damages, attorney’s fees, and litigation expenses.

Review of Factual Findings and Evidence

The Supreme Court, using the 1987 Philippine Constitution as the applicable law, acknowledged its jurisdiction to review factual issues in cases of conflicting findings between lower courts. The Court found no stipulation that the truck hit the post; the pre-trial order only admitted the truck’s involvement in the accident. Meralco’s testimonies of Fernandez and SPO2 Galang were hearsay and lacked probative value. However, the firsthand eyewitness testimony of Elmer Abio, the jeepney driver, was credible and unchallenged, establishing that the truck hit the electricity post. Josefa’s own judicial admissions in pleadings further confirmed this fact.

Application of Res Ipsa Loquitur and Presumption of Negligence

The Court applied the doctrine of res ipsa loquitur, whereby an accident involving an unusual event—such as a truck hitting a stationary electricity post—implies negligence on the part of the person with exclusive control of the instrumentality (the truck and driver). The doctrine shifted the burden of proof to Josefa to show absence of negligence, which he failed to do. Josefa’s failure to present evidence or prove contributory negligence from other motorists reinforced the presumption of Bautista’s negligence as proximate cause.

Vicarious Liability of Josefa

Given Bautista’s negligence, the Court held Josefa vicariously liable under Article 2180, paragraph 5 of the Civil Code, which imputes employer liability for damages caused by employees acting within the scope of their tasks. Josefa's denial of the employment relationship was insufficient without proof that the truck was used without authorization or stolen. Registered vehicle ownership carries the presumption of control and responsibility. Josefa also failed to prove he exercised the diligence of a good father of a family in hiring and supervising Bautista, especially after waiving presentation of evidence.

Meralco’s Claim for Actual Damages, Attorney’s Fees, and Litigation Expenses

Despite establishing liability, the Court found Meralco failed

Case Syllabus (G.R. No. 182705)

Case Background and Factual Antecedents

On April 21, 1991, at approximately 1:45 p.m., a vehicular accident occurred along Ortigas Avenue, Pasig City involving a dump truck, a jeepney, and a car.
The accident resulted in the damage of a 45-foot wooden electricity post, three 75 KVA transformers, and other electrical line attachments owned by Manila Electric Company (Meralco).
Meralco, upon investigation, determined that the dump truck bearing plate number PAK-874, registered under Vicente Josefa's name, was the vehicle that struck the electricity post.
Meralco demanded reimbursement from Josefa for the replacement cost of the damaged property, but Josefa declined payment.
Consequently, Meralco filed a damages suit against Josefa and the truck driver, Pablo Manoco, before the Regional Trial Court (RTC) of Pasig City on September 28, 1993.

Proceedings Before the Regional Trial Court (RTC)

Meralco alleged that reckless driving by Manoco caused the damage and that Josefa was primarily liable due to negligence in managing and supervising Manoco.
The complaint sought actual damages of ₱384,846.00, attorney's fees of ₱50,000.00, litigation expenses of ₱10,000.00, and the costs of suit.
Josefa's defense denied Manoco was his employee at the time and asserted exercising due diligence in his employment practices.
The action included a counterclaim for attorney’s fees due to the allegedly baseless complaint filed by Meralco.
Meralco amended its complaint to correct the driver's name from “Pablo Manoco” to “Pablo Manojo Bautista” but later dropped Bautista as a party due to failed summons service.

Evidence Presented by Meralco

Meralco introduced testimonies from six witnesses and documentary exhibits to substantiate their claim.
Juan Fernandez, Meralco’s senior legal investigator, testified about arriving at the accident scene and gleaning information from bystanders and police personnel identifying the truck owner as Josefa.
Elmer Albio, the jeepney driver involved, provided a first-hand account of the accident, recounting that the truck suddenly hit the rear of his jeepney, which caused a chain collision ending with the truck striking the electricity post.
Police traffic investigators such as SPO2 Manuel Valiente and SPO2 Alexander Galang provided limited and hearsay testimony regarding the accident.
Meralco’s foreman and supervising accountant testified about the replacement work and computed damages, respectively, although some supporting documents were not presented at trial.
The RTC admitted Meralco’s documentary evidence after testimonial presentations.

Evidence and Defense Presented by Josefa

Josefa filed a demurrer to evidence, claiming insufficiency of proof but was denied by the RTC and the appellate Court of Appeals (CA).
Josefa failed to present any evidence-in-chief during trial, resulting in the RTC submitting the case for decision without his evidence due to repeated and unreasonable delays.
Josefa maintained that Meralco’s claim lacked factual support, contending the alleged driver was not his employee and that causation was not established.

RTC Decision

The RTC dismissed Meralco’s complaint, finding insufficient evidence that the truck hit the electricity post.
The court found that police testimonies relied on hearsay and gave no probative value to the police blotter entry.
The RTC also denied Meralco’s claim for actual damages due to lack of subst