First Malayan Leasing and Finance Corporation v. Court of Appeals
REITERATIONFacts
1. The Antecedents: This case concerns liability for a multi-vehicle collision on December 14, 1983, involving an Isuzu cargo truck registered in the name of First Malayan Leasing and Finance Corporation (FMLFC) and driven by Crispin Sicat. The truck collided with a Ford Granada, pushing it into the car of Crisostomo B. Vitug, which was stopped at an intersection. The impact crushed Vitug's car, causing its gas tank to explode and engulf the vehicle in flames. Vitug sustained injuries and lost personal effects, while two passengers in his car died. FMLFC denied ownership and employment of the driver, asserting it had sold the truck to Vicente Trinidad in 1980. 2. Procedural History: Crisostomo B. Vitug filed a civil case against FMLFC for damages. FMLFC filed a third-party complaint against Vicente Trinidad's estate, which admitted the truck was operated by the deceased but claimed the estate was settled. The Regional Trial Court ruled in favor of Vitug, ordering FMLFC to pay damages. FMLFC appealed to the Court of Appeals, which affirmed the trial court's decision but ordered the Estate of Vicente Trinidad to indemnify FMLFC for any amounts paid to Vitug. 3. The Petition: FMLFC filed a petition for review on certiorari with the Supreme Court, seeking to reverse the appellate court's decision. The petition was initially dismissed for failing to comply with procedural requirements, including proof of service and submission of a certified true copy of the appellate court's decision, and for being filed late. Although the petition was reinstated upon motion for reconsideration, the Supreme Court ultimately denied it, holding that the registered owner of a motor vehicle is responsible to the public and third persons for damages caused by its operation, regardless of any alleged sale or transfer of ownership, as such transfers must be registered to be valid against third parties.
Issue(s)
Whether the registered owner of a motor vehicle is liable for damages caused by its operation, notwithstanding an alleged sale or transfer of ownership not recorded in the Land Transportation Office. Whether the factual finding of the lower courts regarding the registration of the vehicle is reviewable by the Supreme Court in a petition for certiorari.
Ruling
The petition is DENIED for lack of merit. The decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the issue of the registered owner's liability: The Supreme Court reiterated the well-settled principle that regardless of who the actual owner of a motor vehicle might be, the registered owner is considered the operator with respect to the public and third persons. As such, the registered owner is directly and primarily responsible for the consequences of its operation. The Court emphasized that in contemplation of law, the owner/operator of record is the employer of the driver, and the actual operator and employer are considered merely as his agent. This doctrine is rooted in the policy to prevent registered owners from evading responsibility by colluding with others or transferring ownership to impecunious individuals. The Court further clarified that for a transfer of ownership of a motor vehicle to be valid against third persons, it must be recorded in the Land Transportation Office. Although a sale may be valid between the parties, it cannot affect third persons who rely on the public registration as conclusive evidence of ownership. Therefore, in the eyes of the law, FMLFC remained the owner and operator of the Isuzu cargo truck and was fully liable to third parties injured by its operation due to the driver's fault or negligence. On the reviewability of factual findings: The Supreme Court held that the factual finding of the trial court and the Court of Appeals that the Isuzu vehicle was still registered in the name of FMLFC at the time of the accident is not a matter that can be reviewed by the Supreme Court in a petition for certiorari under Rule 45 of the Rules of Court. Such petitions are generally limited to questions of law, and the Court does not typically re-examine evidence or findings of fact made by lower courts, especially when they are consistent.
Main Doctrine
The registered owner of a motor vehicle is considered the operator thereof with respect to the public and third persons, and is therefore directly and primarily responsible for the consequences of its operation, regardless of any alleged sale or lease made thereon. For a transfer of ownership to be valid against third persons, it must be recorded in the Land Transportation Office.