Mercury Drug v. Huang
REITERATIONFacts
The Antecedents: A road accident occurred on December 20, 1996, involving a six-wheeler truck owned by Mercury Drug Corporation (Mercury Drug) and driven by Rolando J. del Rosario, and a car owned by Spouses Richard and Carmen Huang, driven by their son Stephen Huang. The truck, while traversing the C-5 Highway, suddenly swerved to its left and collided with the front right side of the car. The collision caused the car to be hurled over the island, hit a lamppost, spin, and land on the opposite lane. The truck also hit a lamppost and ran over the car before stopping. At the time of the accident, Del Rosario's driver's license had been confiscated due to a prior apprehension for reckless driving, and he was holding a Traffic Violation Receipt (TVR). Procedural History: The Regional Trial Court (RTC) of Makati City found Mercury Drug and Del Rosario jointly and severally liable for damages. The Court of Appeals (CA) affirmed the RTC decision with modification, reducing the award for moral damages. The case was elevated to the Supreme Court on appeal. The Petition: Petitioners Mercury Drug and Del Rosario sought to set aside the CA decision, alleging reversible errors, including the denial of their motion for reconsideration, according greater weight to respondents' evidence, disregarding petitioners' evidence, awarding damages, finding Mercury Drug negligent in supervision, and finding Del Rosario negligent.
Issue(s)
Whether petitioner Rolando J. del Rosario was negligent in driving the truck. Whether petitioner Mercury Drug Corporation exercised the diligence of a good father of a family in the selection and supervision of its employee, Rolando J. del Rosario. Whether the damages awarded by the lower courts are proper and supported by evidence.
Ruling
The Supreme Court affirmed the findings of the RTC and the Court of Appeals. It held that petitioner Del Rosario was negligent and that petitioner Mercury Drug failed to exercise the diligence of a good father of a family in the selection and supervision of its employee. The awards for damages were upheld, with the reduction of moral damages by the Court of Appeals being maintained.
Ratio Decidendi
On the negligence of petitioner Rolando J. del Rosario: The Court found that the evidence proved Del Rosario's negligence as the direct and proximate cause of the injuries. Petitioner Del Rosario's testimony regarding the car bumping the truck's front right tire and the car landing on the opposite lane was contradicted by physics expert testimony and the physical evidence. The expert opined that given the weight difference and direction of travel, if the car hit the truck's front right, the car would generally move to the right, not the left. Furthermore, Del Rosario admitted to losing control of the truck and failing to apply brakes after the impact, which was inconsistent with the speed and the alleged cause of the accident. The Court concluded that Del Rosario failed to act as a reasonable and prudent man under the circumstances. On the liability of petitioner Mercury Drug Corporation: The Court reiterated that an employer is liable under Article 2180 of the Civil Code unless it proves it exercised the diligence of a good father of a family in the selection and supervision of its employees. Mercury Drug failed to discharge this burden. Regarding selection, Del Rosario did not undergo the same tests for a truck driver position as he did for a delivery man, and the tests used a light vehicle, not a truck. No NBI or police clearances were presented, and the last relevant seminar attended was twelve years prior to the accident. Regarding supervision, Del Rosario was driving without a license, holding only a TVR for reckless driving, and despite reporting this to his superior, no disciplinary action was taken. The company also did not have a policy for back-up drivers for long trips, and Del Rosario had been driving for over thirteen hours without an alternate. On the damages awarded: The Court upheld the award of actual damages, finding them supported by receipts for hospital expenses, medicines, medical services, and nursing care. The award for compensatory damages, specifically life care cost and lost earning capacity, was also affirmed, considering the permanent paralysis of Stephen Huang and his bleak future, supported by medical prognosis and his excellent academic and extracurricular background. The Court also upheld the awards for moral damages, recognizing the intense suffering of Stephen and his parents, and exemplary damages, given Del Rosario's gross negligence. Attorney's fees were also granted as respondents were compelled to litigate to protect their interests.
Main Doctrine
An employer is vicariously liable for the damages caused by the negligence of its employee in the service of the branches in which the latter are employed or on the occasion of their functions, unless the employer can prove it exercised the diligence of a good father of a family in the selection and supervision of said employee. The employer must present concrete proof, including documentary evidence, to establish compliance with these requirements.