Case Summary (G.R. No. 224186)
Background and Origin of the Case
The petitioners filed a complaint for damages rooted in the Civil Code, particularly Articles 2184 and 2180, against the respondent, its related company Power Supply, and the company driver, Bosquit. The petitioners alleged vicarious liability on the part of Hanna Via Design & Construction for the negligent driving by Bosquit that caused a collision involving petitioners' Ford Ranger Pick-Up, resulting in serious physical injuries and prolonged hospitalization at Davao Doctors Hospital.
Procedural History and Jurisdictional Challenge
After the petitioners' presentation of evidence, the respondent moved for a demurrer to evidence, questioning among other things, the jurisdiction of the Regional Trial Court (RTC) of Malolos City. The respondent contended that the complaint was essentially a criminal complaint for reckless imprudence and that the proper venue was in Davao City, where the accident occurred. The RTC denied this demurrer, sustaining its civil jurisdiction over the complaint and emphasizing that ownership and liability issues were factual questions.
Court of Appeals (CA) Decision and Rationale
The respondent elevated the jurisdictional question to the CA through a petition for certiorari. The CA acknowledged the RTC’s territorial jurisdiction but reversed the denial of the demurrer to evidence. The CA found grave abuse of discretion by the RTC because the registered owner of the subject vehicle was established as Power Supply, not Hanna Via Design & Construction. Under the registered owner rule, the CA held that Hanna Via was not liable, resulting in dismissal of the complaint against it.
Key Issue: Propriety of the Denial of the Demurrer to Evidence
The principal legal issue for the Supreme Court’s review was whether the RTC properly denied the demurrer to evidence filed by respondent. Petitioners argued that the CA erred in admitting the petition for certiorari, as the order denying the demurrer was interlocutory and not subject to such remedy.
Supreme Court's Analysis on the Remedy and Jurisdiction
The Court clarified that an order denying a demurrer to evidence is interlocutory and not appealable under Rule 41 of the Rules of Court. However, it may be assailed via a petition for certiorari under Rule 65 if grave abuse of discretion is alleged. The Court affirmed that certiorari was the proper remedy and undertook judicial review to determine whether there was grave abuse of discretion in the denial of the demurrer.
Definition and Purpose of Demurrer to Evidence
The Court reiterated the legal definition of a demurrer to evidence as a procedural objection asserting that the adversary’s evidence is legally insufficient to sustain the case or issue, regardless of its truth. This serves as a test of whether the plaintiff has made out a prima facie case warranting trial continuation.
Supreme Court’s Agreement with CA on Grave Abuse of Discretion
On review, the Supreme Court agreed with the CA that the RTC acted with grave abuse of discretion by ignoring the registered owner rule. The vehicle’s Certificate of Registration listed Power Supply as the registered owner, a critical factor that the RTC failed to apply correctly in denying the demurrer.
Explanation and Policy Behind the Registered Owner Rule
The Court explained the registered owner rule, established under Act No. 3992 and supported by jurisprudence, which makes the registered owner of a motor vehicle primarily liable for damages caused by its operation to protect the public. The purpose of registration is not to transfer ownership but to identify the owner for accountability in accidents. This identification facilitates the prompt and definite imposition of responsibility and indemnification without needing to establish actual ownership or driver identity.
Limits and Balancing of the Registered Owner Rule
The Court underscored that while the registered owner is directly liable, this responsibility does not exonerate the real or actual own
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Case Syllabus (G.R. No. 224186)
Background and Procedural History
- The case arose from a complaint for damages filed by spouses Emilio Mangaron, Jr. and Erlinda Mangaron against Hanna Via Design & Construction, Power Supply and Equipment Parts (Power Supply), and their company driver, Crestino T. Bosquit.
- The complaint invoked vicarious liability under Article 2184, in relation to Article 2180 of the Civil Code, due to the negligent driving of an Isuzu Truck with Plate Number PLM 612, which struck and dragged the petitioners’ Ford Ranger Pick-Up, causing serious injuries.
- The petitioners were hospitalized for a month at Davao Doctors Hospital as a result of the injuries sustained.
- After the petitioners presented their evidence, the respondent filed a Motion for Demurrer to Evidence, contesting the sufficiency of evidence to support the claim.
- The respondent also questioned the jurisdiction of the Malolos City RTC, arguing the complaint was criminal in nature and should have been filed in Davao City.
Trial Court Rulings and Appeals
- The RTC denied the Motion for Demurrer to Evidence, asserting that ownership and liability issues were evidentiary matters and affirming jurisdiction since the case was civil in nature.
- A Motion for Reconsideration by the respondent was likewise denied by the RTC.
- The respondent filed a Petition for Certiorari with the Court of Appeals (CA) citing lack of jurisdiction and grave abuse of discretion by the RTC.
- The CA upheld RTC’s jurisdiction but reversed the denial of the motion for demurrer to evidence, dismissing the case on grounds that the registered owner of the truck was Power Supply, not the respondent, and thus the respondent could not be held liable.
- Petitioners’ Motion for Reconsideration was denied by the CA, leading to the filing of the present Petition for Review on Certiorari before the Supreme Court.
Issue Presented
- The sole issue before the Supreme Court involved the propriety of the RTC’s denial of the motion for demurrer to evidence filed by the respondent.
Petitioner’s Arguments
- Petitioners contended that the CA erred in granting the Charter remedy of certiorari, arguing that an interlocutory order denying a demurrer to evidence is not a proper subject for such remedy.
- They also argued that there was sufficient basis to deny the motion for demurrer to evidence and proceed with the case.
Supreme Court’s Ruling on the Remedy
- The Supreme Court held that