Case Summary (G.R. No. 144458)
Factual Background
On the evening of May 25, 1992, Atty. Libunao and a companion visited a Mercury Drug Store, where Libunao purchased items and retained the receipt. Upon exiting the store, they were confronted by Sido, the security guard, who demanded to see the receipt. An altercation ensued, wherein Sido verbally assaulted Libunao and allegedly physically assaulted him by hitting him. Following this incident, Sido threatened Libunao with a firearm. Libunao experienced severe trauma, which led to psychiatric treatment for post-traumatic depression syndrome.
Procedural History
After the incident, Libunao filed a complaint for damages before the Regional Trial Court (RTC) against Mercury Drug Corporation and its employees. The RTC ruled in favor of Libunao, awarding him moral and exemplary damages. Mercury Drug Corporation contested the RTC decision, asserting that Sido was not its employee but rather an employee of Black Shield Security Services Corporation (BSSC), emphasizing that they could not be held liable for Sido’s actions under Article 2180 of the New Civil Code.
Court of Appeals Ruling
The Court of Appeals modified the RTC decision, affirming the finding that Mercury Drug Corporation was jointly liable with Sido for the damages awarded to Libunao. The appellate court ruled that Sido was indeed an employee of Mercury Drug based on the circumstances of his assignment to the store and the duties he performed there.
Petition for Review
In response, Mercury Drug Corporation filed a petition for review, raising several key arguments. The petitioner claimed that the Court of Appeals disregarded judicial admissions made during the trial regarding Sido's employment status and that the appellate court misapplied Article 2180 by holding the company liable for Sido’s tortious acts.
Issues for Resolution
The case presented the following legal issues: (1) Whether the certification against forum shopping was sufficient; (2) Whether the remedy sought by the petitioner was appropriate; and (3) Whether Mercury Drug Corporation is liable for the actions of Sido.
Legal Analysis
On the first issue regarding forum shopping certification, the Supreme Court determined that the in-house counsel's certification was valid and adequate, aligning with precedent that allows such representations from corporate counsel.
Regarding the second issue, the Court affirmed that a petition for review under Rule 45 is indeed appropriate for addressing substantial misapprehensions of facts and errors in applying the law.
On the crucial third issue, the Supreme Court concluded that Mercury Drug Corporation was not Sido’s employer and therefore could not be held liable for the alleged wrongful acts Sido committed against Libunao. This finding rested on several factors: the judicial admission from the respon
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Case Overview
- This case involves a petition for review on certiorari filed by Mercury Drug Corporation against Atty. Rodrigo B. Libunao, challenging the decision of the Court of Appeals which modified the ruling of the Regional Trial Court of Quezon City.
- The decision of the Court of Appeals affirmed the trial court's judgment in favor of Libunao, who sought damages for the alleged wrongful acts of a security guard employed by a security agency.
Background of the Case
- On November 24, 1992, Atty. Rodrigo Libunao filed a complaint for damages against Mercury Drug Corporation, its President Mariano Que, Store Manager Vilma Santos, and Security Guard Remigio Sido, in Civil Case No. Q-92-14114.
- Libunao sought P1,000,000.00 in moral damages, P500,000.00 in exemplary damages, reimbursement of fees totaling P250,000.00, and costs of the suit.
Allegations by the Plaintiff
- Libunao's account of the incident occurred on May 25, 1992, at Mercury Drug Store, where he was accosted by Security Guard Sido while exiting the store.
- Sido forcibly demanded to see the receipt for Libunao's purchases, leading to a violent altercation where Sido allegedly struck Libunao and threatened him with a firearm.
- Following the incident, Libunao reported it to the chief of security, leading to Sido's arrest and subsequent trauma requiring psychiatric consultation.