Case Summary (G.R. No. L-22272)
Applicable Law and Proceedings
The case was decided under the laws prior to the 1987 Constitution, the applicable law being the Civil Code provisions before its amendment, specifically Articles 1174 (fortuitous events), 1759 (liability of common carriers), 1764 (compensatory damages), 2206 (liability for breach of contract), and 2210 (interest). The trial court found Perez liable for damages, dismissing the claim against Valenzuela. Both parties appealed. The Court of Appeals affirmed Valenzuela's criminal conviction on May 19, 1964.
Carrier’s Liability and Distinction from Precedent
The defendant Perez cited the case Gillaco v. Manila Railroad Co., which held a carrier is not absolutely liable for assaults committed by its employees if the act was outside the scope of their duty. However, this case is distinguished on facts and law. In Gillaco, the employee’s act occurred outside his duty and prior to his work hours; hence, the employer was not liable. In contrast, in this case, Valenzuela, the driver, committed the killing during the course of his duty as the carrier’s employee, entrusted with transporting the passenger safely.
Statutory Difference and Legal Basis for Liability
The earlier Civil Code used in Gillaco did not impose absolute liability on carriers for willful acts of employees, while the current Civil Code (applicable here) explicitly holds common carriers liable for death or injury to passengers caused by negligence or willful acts of employees, even if beyond their authority or against orders (Art. 1759, Civil Code of the Philippines). This codal provision introduces absolute liability aimed at passenger protection.
Theoretical Foundations for Absolute Liability
The Court explained three main reasons supporting this strict liability: (1) the carrier’s contractual obligation demands exceptional care for passenger safety against violence, especially from its own employees; (2) the carrier delegates to its employees the duty to safeguard passengers and must assume responsibility for their breach; and (3) the carrier, not the passenger, controls employee selection and dismissal, and thus should bear the risk for employee misconduct.
Implications for Carrier's Duty of Care
The carrier must exercise stringent standards in hiring and supervision, including assessing technical competence, physical ability, character, and social disposition of employees entrusted with passenger safety. Accordingly, the Court affirmed the lower court's decision holding Perez liable under Article 1759.
Dismissal of Claim Against Driver Valenzuela
The driver, Valenzuela, was not a party to the contract of carriage and the civil claim did not lie against him; his liability was addressed in the criminal case where he had been convicted. The dismissal of the claim against him in civil court was proper.
Damages Award and Adjustment
The trial court awarded P3,000 as compensatory damages, the minimum under Arts. 1764 and 2206 for breach of contract resulting in death. The Court increased this amount to P6,000 in line with the policy t
...continue readingCase Syllabus (G.R. No. L-22272)
Factual Background and Procedural History
- Rogelio Corachea was a passenger in a taxicab owned and operated by Pascual Perez on October 18, 1960.
- During the ride, Simeon Valenzuela, the taxicab driver, stabbed and killed Rogelio Corachea.
- Valenzuela was prosecuted for homicide in the Court of First Instance of Batangas, found guilty, sentenced to imprisonment, and ordered to indemnify the heirs P6,000.
- An appeal from Valenzuela's conviction was brought before the Court of Appeals.
- While the appeal was pending, Antonia Maranan, Rogelio’s mother and plaintiff-appellant, filed a civil action against Pascual Perez and Simeon Valenzuela seeking damages for the death of her son.
- Defendants claimed the stabbing was in self-defense, alleging the deceased had stabbed the driver first from behind.
- Perez additionally argued that the event was a caso fortuito (fortuitous event) exempting the carrier from liability.
- The trial court ruled in favor of Antonia Maranan and awarded P3,000 damages from Perez; the claim against Valenzuela was dismissed.
- Both Maranan and Perez appealed the ruling, with Maranan seeking increased damages and Perez again asserting non-liability.
- Subsequently, the Court of Appeals affirmed Valenzuela’s conviction; final judgment was entered on May 19, 1964.
Legal Issues Presented
- Whether the taxicab owner (defendant Perez), as a common carrier, is liable for the death of a passenger caused by the driver's intentional assault.
- The applicability of the legal doctrine concerning carrier liability, particularly in light of the differing provisions between the old Civil Code and the new Civil Code regarding fortuitous events and liability for willful acts by employees.
- Whether the killing qualifies as a caso fortuito exempting the carrier from responsibility.
- Appropriate damages to be awarded to the plaintiff.
Carrier Liability and Scope of Employee’s Duty
- The Court distinguished the case from the precedent established in Gillaco v. Manila Railroad Co., 97 Phil. 884, where the employee committed an assault outside the scope of his employment, and the carrier was not held liable.
- In Gillaco, the assault was considered a fortuitous event, with the guilty employee acting as a mere passenger and not within his duties.
- In contrast, the present case involved the taxicab driver, entrusted by the carrier to transport the passenger, committing the assault while engaged in his employment duties.
- The killing occurred within the course and scope of the driver’s duty as an employee of the carrier.
- The civil liability of the driver was addressed separately in the criminal case where he was convicted.
Statutory Framework and Comparative Legal Analysis
- The applicable legal provisions are from the new Civil Code of the Philippines, specifically:
- Artic