Mendoza v. Soriano
REITERATIONFacts
The Antecedents: On July 14, 1997, at approximately 1:00 a.m., Sonny Soriano was struck and killed by a Tamaraw FX vehicle driven by Lomer Macasasa while crossing Commonwealth Avenue in Quezon City. The victim was thrown a considerable distance upon impact, and the vehicle stopped significantly further down the road. Macasasa, after a brief inspection of the scene, fled instead of rendering aid or reporting the incident. Soriano was subsequently transported to a hospital by a third party, where he later succumbed to his injuries. A criminal case for reckless imprudence resulting in homicide was recommended against Macasasa. Procedural History: Following the incident, respondents, Sonny Soriano's wife and daughter, filed a civil complaint for damages against both Lomer Macasasa and the vehicle's registered owner, petitioner Flordeliza Mendoza, with the Regional Trial Court (RTC) of Caloocan City. The RTC initially dismissed the complaint against Macasasa upon the respondents' motion. After trial, the RTC also dismissed the case against petitioner Mendoza, finding the victim negligent for crossing improperly and ruling that Mendoza had exercised due diligence in her selection and supervision of Macasasa. The respondents appealed this decision to the Court of Appeals (CA). The CA reversed the RTC's ruling, finding Mendoza liable for damages. The appellate court acknowledged the victim's contributory negligence but held Macasasa negligent for speeding and failing to avoid the collision. It also upheld the presumption of employer negligence under Article 2180 of the Civil Code, as Mendoza failed to present evidence of her diligence. Mendoza's motion for reconsideration was denied by the CA. The Petition: Petitioner Flordeliza Mendoza seeks review of the CA's decision and resolution through a petition for review under Rule 45 of the Rules of Court. She argues that the total amount of damages claimed by the respondents falls outside the jurisdiction of the RTC, contending that certain claims, such as moral damages, lost income, exemplary damages, and attorney's fees, should be excluded when determining the jurisdictional amount. Furthermore, she asserts that with the dismissal of the case against Macasasa, there is no longer a basis for her liability, and that no evidence of Macasasa's negligence was presented. Petitioner prays for the reversal of the CA's decision and the affirmation of the RTC's dismissal of the case.
Issue(s)
Whether the Regional Trial Court had jurisdiction over the case, considering the amounts claimed. Whether petitioner Flordeliza Mendoza is liable for damages arising from the death of Sonny Soriano, despite the dismissal of the complaint against her employee, Lomer Macasasa. Whether the Court of Appeals erred in awarding damages to the respondents, considering Sonny Soriano's contributory negligence.
Ruling
The petition is denied for lack of merit. The Decision of the Court of Appeals dated November 17, 2003, and its Resolution dated May 24, 2004, in CA-G.R. CV No. 69037, are affirmed.
Ratio Decidendi
On the issue of jurisdiction: The Regional Trial Court had jurisdiction over the case. The claims for damages, including moral damages, lost income, and indemnity for death, constitute the main cause of action in an action for quasi-delict. Administrative Circular No. 09-94 clarifies that when claims for damages are the primary relief sought, their amounts are included in determining jurisdictional amount. In this case, the total claims, including damages, exceeded the jurisdictional threshold for the RTC, particularly in Metro Manila. Therefore, the RTC properly exercised its jurisdiction. On the issue of employer's liability: Petitioner Flordeliza Mendoza is liable for damages caused by her employee, Lomer Macasasa. Under Article 2180 of the Civil Code, employers are presumed negligent in the supervision of their employees acting within the scope of their assigned tasks, unless they prove they exercised the diligence of a good father of a family. The records show Macasasa violated traffic rules by speeding and by fleeing the scene without rendering aid, which are presumptions of negligence under Article 2185. Petitioner failed to present evidence of due diligence in supervising Macasasa. Thus, she is directly and separately civilly liable for her failure to exercise due diligence in supervising Macasasa, independent of Macasasa's criminal liability. On the award of damages and contributory negligence: The Court of Appeals did not err in awarding damages. While Sonny Soriano was found to be contributorily negligent for not using the pedestrian overpass, this negligence did not preclude recovery from Macasasa's negligence. As provided in Article 2179 of the Civil Code, contributory negligence mitigates, but does not bar, recovery. The CA correctly reduced the awarded damages by 20% to account for Soriano's contributory negligence, a ruling affirmed by the Supreme Court.
Main Doctrine
An employer is directly and separately civilly liable for damages caused by their employee acting within the scope of their assigned tasks, arising from quasi-delict, due to the presumed negligence in supervision, unless the employer proves they exercised the diligence of a good father of a family. The claim for damages in an action for quasi-delict is the main cause of action and must be considered in determining the court's jurisdiction.