Aguilar, Sr. v. Commercial Savings Bank
REITERATIONFacts
The Antecedents: Petitioner Conrado Aguilar, Sr. is the father of Conrado Aguilar, Jr., the victim of a vehicular accident. On September 8, 1984, at approximately 11:15 P.M., Aguilar, Jr. and his companions were crossing Zapote-Alabang Road after a snack. A Lancer car, registered in the name of respondent Commercial Savings Bank (Comsavings) and driven by co-respondent Ferdinand G. Borja, overtook a passenger jeepney and hit Aguilar, Jr. and Nestor Semella. Aguilar, Jr. was thrown against the Lancer's windshield, and the vehicle did not stop. Aguilar, Jr. was pronounced dead on arrival at the hospital. Procedural History: Petitioner filed a complaint for damages against respondents Borja and Comsavings. Borja was declared in default. The trial court found both defendants liable, ordering them jointly and severally to pay actual damages, moral damages, loss of earning capacity, and attorney's fees. The trial court also ordered Borja to indemnify Comsavings for any amount it may pay to the plaintiff. Respondent bank appealed to the Court of Appeals. The Petition: The Court of Appeals reversed the trial court's decision concerning Comsavings, dismissing the complaint against it. The appellate court found no evidence that Borja was performing his assigned tasks for the bank at the time of the mishap. Petitioner filed a petition for review, arguing that the Court of Appeals erred in disregarding the fact that Comsavings was the registered owner of the car, which should render it liable for damages.
Issue(s)
Whether respondent bank, as the registered owner of the vehicle, is liable for damages despite the absence of an employer-employee relationship or proof that the driver was acting within the scope of his employment. Whether the Court of Appeals erred in reversing the trial court's decision and dismissing the complaint against respondent bank.
Ruling
The petition is GRANTED. The assailed decision of the Court of Appeals is REVERSED, and the judgment of the Regional Trial Court is UPHELD. Costs against respondent bank.
Ratio Decidendi
On the issue of the registered owner's liability: The Supreme Court held that the registered owner of any vehicle, even if not for public service, is primarily responsible to third persons for deaths, injuries, and damages it caused. This principle is firmly established in jurisprudence, citing BA Finance Corporation vs. Court of Appeals and Erezo vs. Jepte. The Court emphasized that the primary aim of motor vehicle registration is to identify the owner so that responsibility can be fixed in case of accidents. Allowing the registered owner to evade responsibility by proving a transfer or sale would frustrate the law's purpose of protecting the public. The Court reiterated that the registered owner cannot escape primary liability for damages caused by the vehicle as long as it remains registered in their name. The registered owner's recourse is to file a third-party complaint against the actual tortfeasor or transferee. Therefore, respondent bank, as the registered owner, could not escape primary liability for the death of petitioner's son. On the Court of Appeals' error: The Supreme Court found that the Court of Appeals erred in reversing the trial court's decision and dismissing the complaint against the bank. The appellate court's conclusion that the bank was not liable because there was no proof that Borja was performing his assigned tasks or acting as the bank's vice-president at the time of the accident was contrary to established jurisprudence. The Court clarified that the existence or absence of an employer-employee relationship or proof of acting within the scope of assigned tasks is immaterial when determining the liability of the registered owner. The fact that Borja was driving the car, which was registered in the bank's name, was sufficient to establish the bank's primary liability. The bank's claim that Borja had already bought the car on installment was also insufficient to absolve it of liability as the registered owner.
Main Doctrine
The registered owner of a vehicle is primarily responsible to third persons for damages caused by the operation of said vehicle, regardless of whether the driver was acting within the scope of employment or if the vehicle had been sold or transferred. The registered owner's recourse is against the actual tortfeasor or transferee.