Samala v. Victor
REITERATIONFacts
The Antecedents: On February 7, 1976, Emerita C. Jumanan was a passenger in a jeepney bound for Manila. While the jeepney was making a left turn, a delivery panel truck, after being violently bumped from behind by a Saint Raphael Transit passenger bus, swerved into the path of the oncoming jeepney. The collision caused injuries to several passengers, including Emerita C. Jumanan, who sustained contusions and a fracture. Procedural History: Emerita C. Jumanan, assisted by her husband, filed a complaint for damages against the owners and driver of the jeepney. The jeepney owners denied liability, attributing the collision to the negligence of the owner and driver of the Saint Raphael Transit bus. Consequently, they filed a third-party complaint against the owner (Purificacion Samala) and driver (Leonardo Esguerra) of the bus, and a fourth-party complaint against the bus's insurer. The insurer was declared in default. The trial court absolved the original defendants and ordered the third-party defendants (Samala and Esguerra) and the fourth-party defendant (insurer) to pay damages to the plaintiffs. The Petition: Purificacion Samala and Leonardo Esguerra, the third-party defendants, appealed the decision, arguing that since the principal defendants were absolved, they should also be absolved, and that the plaintiffs could not recover from them on a quasi-delict cause of action when their claim against the defendants was based on breach of contract of carriage.
Issue(s)
Whether the third-party defendants can be held liable to the plaintiffs when the principal defendants have been absolved, considering the nature of a third-party complaint and direct liability. Whether the plaintiffs, who sued on breach of contract of carriage, can recover from the third-party defendants on a cause of action based on tort or quasi-delict, and the implications for avoiding circuity of action.
Ruling
The Supreme Court dismissed the appeal. It affirmed the decision of the lower court, holding Purificacion Samala and Leonardo Esguerra jointly and severally liable with the insurer to pay damages to the plaintiffs.
Ratio Decidendi
On the issue of liability of third-party defendants despite absolution of principal defendants: The Court clarified the nature of a third-party complaint under Section 16, Rule 6 of the Revised Rules of Court. It explained that a third-party defendant can be impleaded not only for contribution, indemnity, or subrogation but also on the ground of direct liability to the plaintiff. In this case, the third-party complaint alleged direct liability of the third-party defendants due to the recklessness and negligence of the bus driver. Therefore, it is not indispensable for the defendant to be first adjudged liable to the plaintiff before the third-party defendant can be held liable to the plaintiff, especially when the theory of the defendant is that the third-party defendant is directly liable. The third-party defendant is bound by the adjudication between the plaintiff and the third-party defendant. On the issue of recovery based on quasi-delict when the original claim was for breach of contract: The Court held that it is immaterial that the third-party plaintiff asserts a cause of action against the third-party defendant on a theory different from that asserted by the plaintiff against the defendant. The primary purpose of the rule on third-party complaints is to avoid circuity of action and to dispose of the entire subject matter arising from a particular set of facts in one litigation. It has been held that a defendant in a contract action may join as third-party defendants those liable to him in tort for the plaintiff's claim against him or directly to the plaintiff. Since the incident was found to be caused by the negligence of the appellant Leonardo Esguerra, the owner Purificacion Samala was also held liable.
Main Doctrine
A third-party complaint may implead a person directly liable to the plaintiff, not merely for indemnification, contribution, or subrogation to the defendant. In such cases, the third-party defendant is bound by the adjudication between the plaintiff and the third-party defendant, and it is not indispensable that the defendant be first adjudged liable to the plaintiff.