Metro Manila Transit Corporation v. Court of Appeals
REITERATIONFacts
The Antecedents: On December 24, 1986, Florentina Sabalburo, while crossing St. Andrews Street and Domestic Road in Pasay City, was hit by an MMTC bus driven by Apolinario Ajoc. The victim was on her way to buy foodstuffs for Noche Buena. Eyewitnesses stated that the traffic light was red for vehicles on St. Andrews Street, and the victim and her companions had started to cross when the bus, moving at a fast speed, struck the victim. Florentina Sabalburo sustained severe injuries and succumbed to them on January 3, 1987. Procedural History: Private respondents filed a complaint for damages against MMTC and Ajoc, alleging that Ajoc drove the bus in a wanton and reckless manner, causing the victim's death. Petitioners denied liability, asserting the victim's own negligence was the proximate cause. The Regional Trial Court (RTC) ruled in favor of the private respondents, ordering petitioners to pay actual damages, loss of earning capacity, moral damages, exemplary damages, and attorney's fees. The Court of Appeals (CA) affirmed the RTC decision in toto. Petitioners' motion for reconsideration was denied. The Petition: Petitioners argue that Article 2179 of the Civil Code should apply, as the victim's own negligence was the immediate and proximate cause of her death. They speculate that the victim's thoughts were preoccupied with Noche Buena preparations, leading her to cross carelessly. They also contend that MMTC should not be held vicariously liable as it exercised diligence in the selection and supervision of its drivers, citing Ajoc's act of bringing the victim to the hospital as proof.
Issue(s)
Whether Article 2179 of the Civil Code, concerning the victim's own negligence as the proximate cause of injury, is applicable. Whether MMTC is solidarily liable for the damages caused by its employee, Apolinario Ajoc, under Article 2180 of the Civil Code.
Ruling
The petition is dismissed. The decision of the Court of Appeals affirming the trial court's judgment is affirmed in toto. Petitioners are ordered to pay damages as determined by the lower courts.
Ratio Decidendi
On the applicability of Article 2179: The Court held that Article 2179 of the Civil Code is not applicable in this case. The petitioners' claim that the victim's mind was preoccupied with Noche Buena preparations is pure conjecture without any evidentiary support. The findings of the trial court and the Court of Appeals, which are binding on the Supreme Court, established that the immediate and proximate cause of the victim's death was the negligent and careless driving by petitioner Ajoc. The Court reiterated that the issue of negligence is a question of fact, and it is not a trier of facts, though it can review factual findings if not supported by evidence. The evidence supported the conclusion that Ajoc's failure to see the victim and her companions proved his recklessness and lack of caution. On the vicarious liability of MMTC under Article 2180: The Court affirmed the solidary liability of MMTC for the acts of its driver, Ajoc. It reiterated the presumption juris tantum that an employer is negligent if an employee's act causes damage, either in selection (culpa in eligiendo) or supervision (culpa in vigilando). To escape this liability, the employer must present convincing proof of exercising the diligence of a good father of a family. MMTC failed to rebut this presumption. The act of bringing the victim to the hospital was post-negligence and not entirely voluntary. Furthermore, MMTC's evidence of company policies on driver screening and seminars was insufficient because they failed to show that Ajoc actually underwent such screening or attended the seminars. The Court emphasized that mere formulation of policies without proof of compliance is not enough to exempt an employer from liability. As a government-owned public utility, MMTC's failure to prove diligence warranted the imposition of liability under Article 2180.
Main Doctrine
An employer is vicariously liable for the damages caused by the negligence of its employee acting within the scope of their assigned tasks. To escape liability under Article 2180 of the Civil Code, the employer must prove that it exercised the diligence of a good father of a family in the selection and supervision of its employees, which includes showing that the employee actually underwent the required screening and training.