Case Summary (G.R. No. 179382)
Petitioner
Spouses Benjamin C. Mamaril and Sonia P. Mamaril
Respondents
• Boy Scout of the Philippines (BSP)
• AIB Security Agency, Inc. (AIB)
• Cesario PeAa
• Vicente Gaddi
Key Dates
• 1971 – Spouses Mamaril begin parking in BSP compound
• September 23, 1976 – Guard Service Contract between BSP and AIB
• May 26–27, 1995 – One jeepney is stolen from BSP compound
• November 20, 1996 – Complaint filed before RTC of Manila, Branch 39
• November 28, 2001 – RTC decision awarding damages to petitioners
• June 11, 2002 – RTC modification reducing vehicle cost award
• May 31, 2007 – Court of Appeals decision modifying RTC ruling
• August 16, 2007 – CA resolution denying reconsideration
• January 14, 2013 – Supreme Court decision
Applicable Law
• 1987 Philippine Constitution (decision rendered post-1990)
• Civil Code of the Philippines:
– Art. 20 (liability for intentional or negligent acts)
– Art. 2176 (quasi-delict)
– Art. 2180 (vicarious liability)
– Art. 1311 (relativity of contracts; stipulation pour autrui)
– Art. 1643 (definition of lease)
– Art. 1654–1664 (lessor obligations; liability for third-party trespass)
Facts of Loss and Parking Arrangement
Since 1971, the Mamarils paid BSP P300.00 per month, per jeepney, to park within BSP’s Malate compound. On the evening of May 26, 1995, six jeepneys were parked there; the next day, one vehicle (Plate No. DCG 392) was missing. Guards PeAa and Gaddi admitted allowing a familiar-looking person to drive it out, in violation of their agreement to admit only owners’ authorized drivers.
Initial Complaint and Trial Court Findings
On November 20, 1996, the Mamarils sued BSP, AIB, PeAa, and Gaddi for: (a) vehicle value and accessories (P300,000.00); (b) daily income loss (P275.00/day); (c) exemplary and moral damages; (d) attorney’s fees; and (e) costs. The RTC (Nov. 28, 2001) found gross negligence by AIB’s guards and contractual indemnity by AIB, holding BSP, AIB, PeAa, and Gaddi jointly liable. It awarded P300,000.00 for vehicle and accessories, P275.00/day income loss, P50,000.00 each for moral and exemplary damages, P50,000.00 attorney’s fees, and P1,500.00 appearance fees. On June 11, 2002, the RTC reduced the vehicle cost award to P200,000.00. BSP alone appealed.
Court of Appeals Decision
The CA affirmed negligence by PeAa and Gaddi and joint liability of AIB and its guards. It absolved BSP, holding that: (1) the Guard Service Contract between BSP and AIB did not confer obligations in favor of third parties; (2) the parking arrangement constituted a lease, not bailment; (3) BSP was not insurer of lessees’ vehicles; and (4) claims for accessories, daily income loss, moral and exemplary damages, and attorney’s fees lacked proof.
Issues on Appeal
- Whether BSP may be held liable for the loss based on the Guard Service Contract and parking ticket.
- Whether the CA erred in deleting awards for accessories, income loss, moral and exemplary damages, and attorney’s fees.
Supreme Court’s Analysis on Liability of BSP
The proximate cause of loss was negligence by AIB guards (Art. 2176), undisputed even after investigation. BSP committed no negligent act or omission; there was no employer–employee or principal–agent relationship between BSP and the guards. Hence, BSP cannot incur vicarious liability under Art. 2180 or agency liability under Art. 1868.
Principle of Relativity of Contracts and Stipulation pour autrui
Under Art. 1311, contracts bind only parties, their assigns, and heirs. A stipulation pour autrui requires a deliberate, unconditional, and uncompensated benefit to a third party, accepted prior to revocation. The Guard Service Contract contained no such stipulation in favor of the Mamarils, who were non-parties and never accepted any benefit thereunder.
Lease Relationship and Obligations of Lessor
The parking arrangement—payment of a fixed fee with key retention by the Mamarils—constituted a lease (Art. 1643). As lessor, BSP was only obliged to maintain the premises’ fitness for parking (Art. 1654) and was not liable for third-party trespa
...continue readingCase Syllabus (G.R. No. 179382)
Antecedent Facts
- Spouses Benjamin C. Mamaril and Sonia P. Mamaril (Sps. Mamaril) have operated six-passenger jeepneys since 1971.
- They parked their vehicles nightly at the Boy Scout of the Philippines (BSP) compound in Malate, Manila, paying a monthly fee of ₱300.00 per unit.
- On May 26, 1995, all jeepneys were parked inside the BSP premises; the next morning, one jeepney (Plate No. DCG-392) was missing and never recovered.
- BSP had contracted AIB Security Agency, Inc. (AIB) to provide guards Cesario PeAa and Vicente Gaddi for its compound’s security.
- The security guards admitted during investigation that they negligently allowed a familiar-looking stranger to drive the jeepney out of the compound.
Procedural History
- November 20, 1996: Sps. Mamaril filed a complaint for damages (Civil Case No. 96-80950) against BSP, AIB, PeAa, and Gaddi before the RTC of Manila, Branch 39.
- They prayed for:
• Value of lost vehicle and accessories (₱300,000.00)
• Daily loss of income (₱275.00/day)
• Exemplary and moral damages
• Attorney’s fees and cost of suit - BSP denied liability, citing the parking ticket’s exculpatory clause and the limited scope of the Guard Service Contract. AIB and the guards likewise denied fault or asserted due diligence and impersonation by the driver.
- November 28, 2001: RTC rendered judgment in favor of Sps. Mamaril, holding BSP, AIB, PeAa, and Gaddi jointly and severally liable.
- June 11, 2002: RTC modified the award, reducing the value of the vehicle from ₱250,000.00 to ₱200,000.00.
- BSP alone appealed to the Court of Appeals (CA).
Issues on Appeal
- Whether BSP is liable for the loss of the jeepney under the Guard Service Contract or as lessor of parking space.
- Whether the exculpatory clause in the BSP-issued parking ticket is valid.
- Whether Sps. Mamaril are entitled to accessory value, lost-income damages, moral/exemplary damages, and attorney’s fees.
Court of Appeals Ruling
- Affirmed negligence of AIB guards PeAa and Gaddi.
- Absolved BSP from liability:
• The Guard Service Contract was purely between BSP and