Jereos v. Court of Appeals
REITERATIONFacts
The Antecedents: On February 23, 1971, a jeepney driven by Narciso Jaravilla, operating under a certificate of public convenience held by Domingo Pardorla, Jr., hit Judge Jesus S. Rodriguez and his wife, Soledad, while they were crossing a street in Iloilo City. Judge Rodriguez died as a result of the injuries sustained. Narciso Jaravilla was convicted of Homicide and Physical Injuries through Reckless Imprudence. Procedural History: Soledad Rodriguez and her children filed an action for damages against Narciso Jaravilla, Domingo Pardorla, Jr., and Angel Jereos, the alleged actual owner of the jeepney. Angel Jereos denied ownership, claiming he sold the jeepney on November 19, 1970, to Flaviana Tanoy, who later transferred ownership to Domingo Pardorla, Jr. Domingo Pardorla, Jr. claimed he was merely the franchise owner and that Angel Jereos operated the jeepney under the 'kabit system.' The Court of First Instance of Iloilo exonerated Angel Jereos, finding no credible evidence that he was the operator at the time of the accident and noting the sale and registration documents. Both plaintiffs and defendants Pardorla, Jr. and Jaravilla appealed. The Petition: The Court of Appeals modified the trial court's decision, holding Angel Jereos jointly and severally liable with the other defendants, finding the sale to Flaviana Tanoy and subsequent registration to be simulated transactions designed to place Jereos beyond the reach of creditors. Angel Jereos filed a petition for certiorari with the Supreme Court, arguing that the Court of Appeals erred in finding the sale simulated and him the actual owner, and that the appellate court should not have disturbed the trial court's findings of fact.
Issue(s)
Whether the findings of fact of the Court of Appeals are reviewable by the Supreme Court, given that they contradict the findings of the trial court. Whether the sale of the jeepney by Angel Jereos to Flaviana Tanoy and its subsequent registration in the name of Domingo Pardorla, Jr. were simulated and fictitious transactions. Whether Angel Jereos, as the alleged actual owner, is jointly and severally liable with the driver and registered owner for the damages caused by the operation of the jeepney.
Ruling
The petition is DENIED. Angel Jereos is held jointly and severally liable with the other defendants for the damages awarded.
Ratio Decidendi
On the reviewability of findings of fact: The Supreme Court held that while generally findings of fact of the Court of Appeals are final and not reviewable, a minute scrutiny is in order when these findings contradict those of the trial court. In this case, the Court of Appeals had reason to exercise its appellate jurisdiction because the trial court relied solely on the deed of sale, ignoring testimonies that suggested otherwise. The appellate court's modification of the trial court's findings was justified by the evidence presented. On the simulated nature of the sale: The Court affirmed the Court of Appeals' finding that the sale of the jeepney was simulated and fictitious. This conclusion was based on the testimonies of Domingo Pardorla, Jr. and Flora Jaravilla, which were corroborated by Adriano Saladero. These testimonies indicated that the transactions were part of a scheme to place Angel Jereos beyond the reach of his creditors, particularly in light of a pending case against Imelda Mirasol, whose units were previously involved in an accident. Jereos's fear of his jeepney being attached was a key motive. On the liability of the actual owner: The Court clarified that the rule in Vargas vs. Langcay, which holds the registered owner jointly and severally liable with the driver, does not exempt the actual owner from liability. The Court reiterated the principle followed in cases like Erezo vs. Jepte and Tamayo vs. Aquino, that the registered owner has the right to be indemnified by the real or actual owner for any damages paid. Therefore, Angel Jereos, as the actual owner, remains liable for the damages caused by the operation of the jeepney, irrespective of the simulated sale.
Main Doctrine
The registered owner of a passenger vehicle is jointly and severally liable with the driver for damages, but this does not exempt the actual owner from liability, especially when the sale of the vehicle was simulated to place the owner beyond the reach of creditors.