Case Summary (G.R. No. 90786)
Key Dates and Procedural Milestones
Complaint filed in RTC Malolos, Branch 11 (Civil Case No. 103-M-2011).
RTC Order denying demurrer to evidence: May 20, 2014; Motion for reconsideration denied: September 26, 2014.
Court of Appeals Decision granting certiorari relief in part and dismissing the case against the respondent (on the basis that the registered owner was Power Supply): October 20, 2015; CA Resolution denying reconsideration: April 14, 2016.
Supreme Court review: Petition for Review on Certiorari filed by petitioners.
Applicable Law and Authorities
Constitutional basis: 1987 Constitution (applicable to cases decided in or after 1990).
Statutory and doctrinal authorities: Articles 2180 and 2184, Civil Code; Act No. 3992 (motor vehicle registration); Rules of Court (Rule 41 on appeals; Rule 65 certiorari); jurisprudence on demurrer to evidence and the registered-owner rule (cases cited in the decision such as FEB Leasing v. Spouses Baylon; Metro Manila Transit v. Cuevas; Equitable Leasing v. Suyom; Filcar Transport v. Espinas).
Factual Background
An Isuzu truck (plate PLM 612) allegedly driven negligently by Bosquit collided with and dragged petitioners' Ford Ranger (plate XJZ-830) in Davao City. Petitioners suffered serious injuries and were hospitalized for about one month. Petitioners filed a civil action for damages against respondent Hanna Via Design & Construction, Power Supply (the truck’s registered owner), and Bosquit (driver), invoking vicarious liability for the driver's negligence.
Motion for Demurrer to Evidence and Trial Court Rulings
After petitioners rested, respondent moved for a demurrer to evidence, contending inter alia that the complaint was criminal in nature (reckless imprudence) and that the RTC lacked jurisdiction because the accident occurred in Davao City. The RTC denied the demurrer, treating ownership, employment relationship and culpability as matters of evidence and affirming its jurisdiction over the civil action. A motion for reconsideration was denied by the RTC.
Court of Appeals Action
Respondent petitioned the CA by certiorari challenging the RTC’s denial of the demurrer. The CA accepted the certiorari petition, held that the RTC’s order was tainted with grave abuse of discretion insofar as it denied the demurrer, and reversed and set aside the RTC orders on the ground that the registered owner of the Isuzu truck was Power Supply, not Hanna Via Design & Construction.
Issue Presented to the Supreme Court
Whether the RTC erred in denying the respondent’s demurrer to evidence, and whether the CA properly entertained and granted certiorari relief to set aside the RTC’s interlocutory order denying the demurrer.
Availability of Certiorari to Challenge an Interlocutory Order
The Court addressed the procedural question whether the CA properly entertained a petition for certiorari to review an interlocutory order. An order denying a demurrer to evidence is interlocutory and generally not appealable under Rule 41. The Court reiterated that, as an exception, a special civil action for certiorari under Rule 65 is available when the interlocutory order is tainted with grave abuse of discretion amounting to lack or excess of jurisdiction. The petition thus qualified for review by certiorari and the Court proceeded to determine whether grave abuse existed.
Nature and Standard of Demurrer to Evidence
A demurrer to evidence challenges the sufficiency in law of the opposing party’s evidence to sustain a cause of action. The proper test is whether, accepting as true all facts and inferences reasonably drawn from the evidence adduced by the plaintiff, the law nonetheless would not afford recovery. The Court examined whether the RTC manifestly abused its discretion in denying the demurrer.
Registered Owner Rule: Legal Principle and Purpose
The Court reaffirmed the registered-owner rule: under compulsory motor vehicle registration statutes, the registered owner of a motor vehicle is directly and primarily responsible, as between the public and third persons, for consequences arising from its operation regardless of the actual owner. The rule’s rationale is administrative and protective — registration identifies a definite person upon whom liability can be fixed so victims may be indemnified without the onerous task of tracing actual ownership. Jurisprudence treats the registered owner as the employer of the driver for purposes of imputing vicarious liability.
Application of the Registered Owner Rule to the Case
The Supreme Court agreed with the CA that the RTC committed grave abuse by failing t
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Citation and Panel
- Supreme Court decision reported at 863 Phil. 731, Second Division, G.R. No. 224186, dated September 23, 2019.
- Decision authored by Justice Reyes, Jr., J.
- Decision concurred in by Carpio (Chairperson), Caguioa, Lazaro-Javier, and Zalameda, JJ.
- Acting Chief Justice designation noted: Acting Chief Justice per Special Order No. 2703 dated September 10, 2019 (as to Carpio).
Parties and Nature of Case
- Petitioners: Spouses Emilio Mangaron, Jr. and Erlinda Mangaron.
- Respondent: Hanna Via Design & Construction, owned and managed by Engr. James Stephen B. Carpe.
- Other named parties in the original complaint: Power Supply and Equipment Parts (Power Supply) and company driver Crestino T. Bosquit.
- Nature of action: Civil complaint for damages filed under Article 2184 in relation to Article 2180 of the Civil Code, invoking vicarious liability for negligent driving.
Facts as Alleged by Petitioners
- The negligent act involved an Isuzu Truck bearing plate number PLM 612 (the subject vehicle).
- The subject vehicle, driven by Bosquit, bumped and dragged petitioners' vehicle, a Ford Ranger Pick-Up with plate number XJZ-830.
- The collision caused serious physical injuries to petitioners.
- Petitioners were confined for a whole month at Davao Doctors Hospital in Davao City.
Procedural History — Trial Court
- Petitioners filed a civil complaint for damages in the Regional Trial Court (RTC), Malolos City, Bulacan, Branch 11 (Civil Case No. 103-M-2011).
- After petitioners rested their case, respondent filed a Motion for Demurrer to Evidence.
- Respondent, among other contentions, questioned the jurisdiction of the RTC, asserting the complaint was actually a criminal action for reckless imprudence resulting in physical injuries and should have been filed in Davao City (the place of the vehicular incident).
- RTC issued an Order dated May 20, 2014 denying respondent's Motion for Demurrer to Evidence.
- RTC rationale: matters raised by respondent (ownership of the subject vehicle, respondent's employment relationship with Bosquit, and respondent's culpability) were matters of evidence to be resolved at trial and not jurisdictional.
- RTC maintained jurisdiction, holding the case was civil in nature — a complaint for damages.
- Respondent filed a Motion for Reconsideration before the RTC, which was denied in an Order dated September 26, 2014.
Procedural History — Court of Appeals
- Respondent filed a Petition for Certiorari before the Court of Appeals (CA) assailing the RTC's denial of the demurrer to evidence.
- Court of Appeals Decision dated October 20, 2015:
- CA upheld the RTC's jurisdiction to hear a civil complaint for damages.
- CA reversed the RTC's denial of the demurrer to evidence, finding grave abuse of discretion by the RTC.
- CA concluded the case should have been dismissed because the registered owner of the subject vehicle was Power Supply, not respondent (application of the registered owner rule).
- CA granted the petition, reversing and setting aside the RTC Orders dated May 20, 2014 and September 26, 2014.
- Petitioners filed a Motion for Reconsideration with the CA, which was denied in a Resolution dated April 14, 2016.
Petition to the Supreme Court
- Petitioners filed a Petition for Review on Certiorari to the Supreme Court, assailing principally:
- (a) The CA's acceptance (giving due course) of the Petition for Certiorari filed by respondent, alleging that certiorari was an improper remedy to challenge an interlocutory order denying a demurrer to evidence.
- (b) The CA's reversal of the RTC's denial of the demurrer to evidence when, according to petitioners, there existed sufficient basis for denial.
Legal Issues Presented
- Whether the Court of Appeals properly gave due course to a Petition for Certiorari challenging an interlocutory order denying a demurrer to evidence.
- Whether the RTC committed grave abuse of discretion in denying respondent's Motion for Demurrer to Evidence.
- Whether the registered owner rule applies to fix liability on the registered owner of the offending motor vehicle notwithstanding respondent's claimed admission of ownership or other factual contentions.
Procedural Law Applied — Remedy for Interlocutory Orders
- Rule 41 (Section 1) of the Rules of Court excludes interlocutory orders from appeal; appeals may be taken only from judgments or final orders that completely dispose of the case.
- Where an order is interlocutory and not appealable, the aggrieved party may file an appropriate special civil action under Rule 65 (writ of certiorari) alleging grave abuse of discretion amounting to lack or excess of jurisdiction.
- The Supreme Court recognized tha