Case Summary (G.R. No. 162267)
Facts of the Case
On the evening of October 19, 1990, a Mitsubishi Lancer owned by UCPB was struck by an 18-wheeler Fuso Tanker Truck owned by PCI Leasing and allegedly operated by Superior Gas Equitable Co., Inc. (SUGECO) and driven by Gonzaga. The collision caused significant damage to the Mitsubishi, resulting in physical injuries to its occupants and an explosion of the vehicle. Despite this, Gonzaga did not take the injured parties to the hospital. UCPB subsequently paid P244,500 for the damages through its insurance coverage and sought reimbursement from PCI Leasing after their demands for payment went unheeded.
Procedural History
UCPB filed a complaint against PCI Leasing and Gonzaga on March 13, 1991. PCI Leasing contended that it should not be liable since Gonzaga was not its employee but that of SUGECO, which was the truck's operator per their lease agreement. The Regional Trial Court (RTC) of Makati City ruled in favor of UCPB, ordering both defendants to pay the insurance company the amount due, along with interest and costs. PCI Leasing appealed the decision to the Court of Appeals (CA), which affirmed the RTC ruling with modifications on December 12, 2003.
Issues Raised
The main legal issues presented by PCI Leasing in its petition pertained to whether it, as the registered owner of the vehicle involved in the accident, could be held jointly liable with the driver Gonzaga for damages caused to third parties. Additionally, the petitioner questioned whether the enactment of Republic Act No. 8556, the Financing Company Act of 1998, absolved it from liability.
Ruling on Liability as Owner
The CA ruled that PCI Leasing could be held liable for the damages resulting from the accident, relying on principles from the Public Service Act. Although the CA acknowledged that the law primarily applies to common carriers, the petitioner is still liable under the civil code regarding the registered owner's obligations. The Court emphasized the longstanding jurisprudential principle that the registered owner of a vehicle is presumed responsible for any damage or injury caused by its operation because registration serves to identify who is liable in the event of an accident.
Compulsory Registration of Vehicles
The Court further explained that the intent behind compulsory registration of motor vehicles is predominantly to ensure accountability for damages resulting from accidents on public highways. The failure to adequately register a transfer, lease, or similar encumbrance does not relieve the registered owner of liability and instead protects the rights of accident victims. In this case, since the lease agreement between PCI Leasing and SUGECO was not registered, PCI Leasing was not allowed to claim that it had transferred responsibility.
The Impact of Republic Act No. 8556
While PCI Leasing argued that Republic Act No. 8556 exempted it from liability, the Court clarified that the new law had not repealed the require
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Case Background
- The case revolves around a Petition for Review on Certiorari under Rule 45 of the Rules of Court, filed by PCI Leasing and Finance, Inc. against UCPB General Insurance Co., Inc.
- The primary objective is to reverse the Decision of the Court of Appeals dated December 12, 2003, which upheld the ruling of the Regional Trial Court of Makati City.
- The RTC had ordered PCI Leasing and Renato Gonzaga to pay UCPB the amount of P244,500.00 plus interest, along with attorney’s fees and costs of suit.
Incident Overview
- On October 19, 1990, a Mitsubishi Lancer (owned by UCPB) was involved in a collision with an 18-wheeler Fuso Tanker Truck (owned by PCI Leasing and operated by SUGECO).
- The accident occurred at approximately 10:30 p.m. on Laurel Highway, resulting in severe damage to the Mitsubishi Lancer and physical injuries to its occupants.
- The driver of the truck, Renato Gonzaga, did not assist the injured parties following the incident.
Insurance Payment and Legal Action
- UCPB, having paid the insurance claim of P244,500.00 for the damaged vehicle, sought reimbursement from PCI Leasing through legal means after multiple demands for payment were ignored.
- PCI Leasing argued that it should not be held liable since Gonzaga was not its employee but that of SUGECO, which operated the truck under a lease agreement.
Judicial Proceedings
- The RTC ruled in favor of UCPB, stating that both PCI Leasing and Gonzaga should pay the claimed amounts.
- PCI Leasing appealed to the CA, which affirmed the RTC’s ruling with modifications