Ma. Luisa Benedicto v. Intermediate Appellate Court and Greenhills Wood Industries Company, Inc.
REITERATIONFacts
The Antecedents: Private respondent Greenhills Wood Industries Company, Inc. (Greenhills) contracted to sell and deliver 100,000 board feet of sawn lumber to Blue Star Mahogany, Inc. (Blue Star). To effect an initial delivery on May 15, 1980, Greenhills' manager contracted Virgilio Licuden, driver of a cargo truck registered in the name of petitioner Ma. Luisa Benedicto (proprietor of Macoven Trucking), to transport 7,690 board feet of sawn lumber. Charge invoices were issued and initialed by the driver. The lumber did not arrive at the consignee's premises, leading Blue Star to look for other suppliers. Procedural History: Greenhills filed a criminal case for estafa against driver Licuden and a civil case against petitioner Benedicto for the value of the lost lumber and attorney's fees. Benedicto denied liability, claiming she had sold the truck to Benjamin Tee prior to the incident and that Licuden was Tee's employee. The Regional Trial Court (RTC) ruled in favor of Greenhills, holding Benedicto liable as the registered owner. The Intermediate Appellate Court (IAC) affirmed the RTC decision. The Petition: Petitioner Benedicto sought to set aside the IAC decision, arguing that the doctrine making the registered owner liable applies only to cases of passenger injury or death, not to carriage of goods, and that a perfected contract of carriage requires delivery and acceptance, which did not occur.
Issue(s)
Whether petitioner Ma. Luisa Benedicto, as the registered owner of the carrier truck, is liable for the value of the undelivered or lost sawn lumber. Whether the doctrine holding the registered owner liable for the negligence of the driver applies to cases involving the carriage of goods, not just passenger safety. Whether a perfected contract of carriage existed under the given circumstances.
Ruling
The Supreme Court denied the Petition for Review for lack of merit and affirmed the decision of the Intermediate Appellate Court, holding petitioner Ma. Luisa Benedicto liable for the cost of the lost sawn lumber and attorney's fees.
Ratio Decidendi
On the liability of the registered owner for lost goods: The Court held that the prevailing doctrine makes the registered owner of a common carrier liable for consequences flowing from the operation of the carrier, even if the vehicle has been transferred to another person. This doctrine is based on the principle that the public has the right to assume the registered owner is the actual owner, and requiring the public to ascertain the actual owner would be practically impossible and defeat the purpose of public policy. The registered owner cannot deny liability by proving a prior sale. Therefore, private respondent was not required to go beyond the certificate of registration to ascertain the owner. On the applicability of the doctrine to carriage of goods: The Court rejected petitioner's contention that the doctrine applies only to passenger safety cases. It emphasized that a common carrier is burdened with the duty of exercising extraordinary diligence in caring for goods transported by it, just as it is for passengers. The loss or destruction of goods raises a presumption of fault or negligence, which can only be overcome by proof of extraordinary diligence. Permitting a carrier to escape responsibility by proving a prior sale would attenuate this duty and open the door to collusion. The public policy behind the doctrine is as sharp and real in the case of carriage of goods as in transporting passengers. On the existence of a perfected contract of carriage: The Court found no merit in petitioner's arguments that no perfected contract of carriage existed. Driver Licuden was entrusted with the truck by the registered owner (and the alleged secret owner), clothing him with implied authority to contract for carriage and accept goods. The failure to fix the freightage before loading did not prevent the contract from arising, as freight is determinable by tariff schedules. Driver Licuden was regarded as the employee and agent of the petitioner, for whose acts she must respond. A contract of carriage was shown, the goods were loaded, and the loss or non-delivery was proven. Petitioner failed to prove extraordinary diligence or that the loss was due to force majeure.
Main Doctrine
The registered owner of a common carrier vehicle is liable for consequences flowing from the operation of the carrier, even if the vehicle has been transferred to another person, based on the principle that the public has the right to assume the registered owner is the actual owner, and to require them to prove otherwise would be practically impossible and would defeat the purpose of public policy.