Case Summary (G.R. No. 147746)
Trial Court Findings and Award
The Regional Trial Court applied the doctrine of res ipsa loquitur to infer Pascual’s negligence in vehicle upkeep and held petitioners jointly and solidarily liable. It found insufficient evidence of corporate supervision. Actual damages of ₱2,904,880 were awarded, covering the residential and commercial buildings and personal property. The court accepted respondents’ valuations—adjusted for depreciation—and granted legal interest from December 12, 1995.
Court of Appeals Ruling and Modification
The Court of Appeals affirmed the application of res ipsa loquitur and corporate vicarious liability but reduced recovery to ₱600,000 as nominal damages under Civil Code Articles 2222–2223, owing to respondents’ failure to substantiate their actual loss. Later, upon respondents’ motion, it set aside the nominal‐damages award and remanded the case to the RTC for reception of additional evidence on actual damages.
Supreme Court’s Analysis on Res Ipsa Loquitur
The Court reaffirmed that, where no direct proof of negligence exists, the happening of an accident not ordinarily occurring without negligence, under the exclusive control of the defendant, gives rise to an inference of negligence. Pascual failed to demonstrate reasonable care in maintaining a 14-year-old vehicle used on provincial trips. The absence of evidence of periodic inspection or servicing defeated his claim of caso fortuito, since mechanical defects do not excuse an employee’s failure to properly maintain a vehicle.
Employer’s Vicarious Liability under Pater Familias Rule
Under Civil Code Article 2180 and established jurisprudence, an employer is liable for damages caused by an employee when it fails to exercise the diligence of a good fat
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Case Background and Procedural History
- G.R. No. 147746, decided October 25, 2005, Third Division, ponente Justice Corona.
- Respondents Gaudencio Sarangaya III and Primitiva Sarangaya owned a semi-concrete, semi-narra, one-storey commercial building (“Super A Building”) fronting the Santiago, Isabela provincial road; they lived in a two-storey residence behind the second and third doors.
- In 1988, petitioners Perla Compania de Seguros, Inc. (the corporation) and its branch manager Bienvenido S. Pascual leased the first door, abutting the Matsushita Electric Philippine Corporation office; they renovated it into an office and a garage for a 1981 Ford Cortina used by Pascual.
- On July 10, 1988, Pascual attempted to start the Cortina after a three-day absence; unusual engine noise, a small flame, and then a sudden fire erupted from the rear compartment, engulfing the garage and trapping Pascual inside.
- Two loud explosions alerted respondents at home; the fire destroyed their house, contents, furniture, appliances, and cash.
- The city fire marshal’s investigation concluded the fire was “accidental” and noted petitioner-corporation lacked a fire permit; a criminal complaint for reckless imprudence was filed against Pascual but later withdrawn.
- Respondents filed a civil quasi-delict complaint seeking damages for destruction of their building, belongings, lost rentals, moral and exemplary damages, and attorney’s fees.
Trial Court Findings and Judgment
- Respondents offered testimony that Pascual had purchased gasoline in a container and stored it in the car’s rear compartment days before the incident.
- Pascual claimed a pure accident (caso fortuito) and denied storing gasoline in the car; the corporation invoked due diligence in selecting and supervising Pascual.
- The Regional Trial Court, Branch 21, Santiago, Isabela:
- Applied the doctrine of res ipsa loquitur to infer Pascual’s negligence in the upkeep of the car despite lack of direct proof of cause.
- Held both Pascual and the corporation failed to prove exercise of requisite care and diligence.
- Ordered joint and solidary payment of ₱2,904,880.00 actual damages with legal interest from December 12, 19