Joseph v. Bautista
REITERATIONFacts
The Antecedents: Petitioner Luis Joseph boarded a cargo truck owned by respondent Patrocinio Perez, driven by Domingo Villa, from Dagupan City to Valenzuela, Bulacan. While the cargo truck was overtaking a tricycle, a pick-up truck, allegedly owned by respondents Antonio Sioson and Jacinto Pagarigan and driven by respondent Lazaro Villanueva, attempted to overtake the cargo truck. This maneuver forced the cargo truck to veer off the road and hit a mango tree, causing petitioner to sustain a leg fracture. Procedural History: Petitioner filed a complaint for damages against Perez (breach of contract of carriage) and against Sioson and Villanueva (quasi-delict). Sioson denied ownership of the pick-up truck. Petitioner amended his complaint to implead Pagarigan and Rosario Vargas as alternative defendants, uncertain of the true owners of the vehicles. Perez filed an amended answer with a cross-claim against co-defendants, impleading Alberto Cardeno as an additional alternative defendant. Subsequently, respondents Villanueva, Cardeno, Sioson, and Pagarigan, through their insurer, paid petitioner P1,300.00, and petitioner executed a release of claim in their favor. Later, Villanueva, Cardeno, and their insurer paid Perez P7,420.61 for damages to her truck. The other respondents then moved to be exonerated, citing the payments and release. Perez opposed, arguing that the release in favor of the other respondents should also benefit her due to their solidary liability. The respondent judge dismissed the case, which was affirmed upon reconsideration. The Petition: Petitioner appealed, contending that the respondent judge erred in holding that the release of claim executed in favor of other respondents inured to the benefit of respondent Perez, and consequently erred in dismissing the case.
Issue(s)
Whether the release of claim executed by the petitioner in favor of respondents Sioson, Villanueva, and Pagarigan inured to the benefit of respondent Perez. Whether the respondent judge erred in dismissing the case.
Ruling
The Supreme Court affirmed the orders of the respondent judge dismissing the case.
Ratio Decidendi
On the issue of whether the release of claim inured to the benefit of respondent Perez: The Court held that the argument that there were two causes of action, thus making the compromise on one not a bar to the other, is untenable. A cause of action is defined as the wrongful act or omission by the defendant in violation of the plaintiff's rights. Even if a single act violates multiple rights, there is only one cause of action if there is only one delict or wrong. In this case, the petitioner sustained a single injury, giving rise to a single cause of action, even though he invoked different legal bases for recovery against different respondents. The Court emphasized that if only one injury resulted from several wrongful acts, only one cause of action arises. Therefore, the trial court correctly found only one cause of action, and recovery under one remedy necessarily bars recovery under another, consistent with the principle against double recovery and unjust enrichment. Furthermore, the Court found no question that the respondents were solidarily liable to the petitioner, as prayed for in the amended complaint and supported by the allegations. Since the respondents were found to be solidarily liable, the full payment made by some of the solidary debtors and their subsequent release from liability inevitably resulted in the extinguishment of the liability of the other solidary debtors, including respondent Patrocinio Perez. The Court also found the claim of a pre-trial agreement to proceed against Perez after payment by others to be incredible and unsubstantiated, as there was no record to support it. On the dismissal of the case: Given the finding that the release of claim executed by the petitioner in favor of some solidary debtors extinguished the liability of the other solidary debtors, including respondent Perez, the dismissal of the case by the respondent judge was deemed correct. The principle against double recovery for the same act or omission, stemming from the rule against unjust enrichment, was applied. The Court reiterated that a single injury gives rise to a single cause of action, and recovery under one remedy bars recovery under another.
Main Doctrine
A single injury resulting from several wrongful acts gives rise to only one cause of action. Recovery under one remedy bars recovery under another, consistent with the principle against double recovery and unjust enrichment. Full payment by some solidary debtors extinguishes the liability of other solidary debtors.