Filipinas Synthetic Fiber v. De los Santos
REITERATIONFacts
The Antecedents: On September 30, 1984, Teresa Elena Legarda-de los Santos, wife of respondent Wilfredo de los Santos, performed in a musical play. Wilfredo requested his brother, Armando de los Santos, to fetch Teresa Elena. Armando drove a company car assigned to Wilfredo, with Teresa Elena and two other cast members as passengers. Around 11:30 p.m., while traveling along Katipunan Road, the car collided with a shuttle bus owned by petitioner Filipinas Synthetic Fiber Corporation (Filsyn) and driven by its employee, Alfredo S. Mejia. The collision caused the car to be dragged, burst into flames, and burn its four occupants beyond recognition. Procedural History: A criminal charge for reckless imprudence resulting in damage to property with multiple homicide was filed against Mejia, which he won. Subsequently, the families of the victims filed separate civil cases for damages against Filsyn and Mejia. The Regional Trial Court (RTC) ruled in favor of the respondents, ordering Filsyn and Mejia to pay actual, compensatory, moral damages, and attorney's fees. The Court of Appeals (CA) affirmed the RTC decision with modification regarding the compensatory damages. Filsyn's motion for reconsideration was denied. The Petition: Filsyn filed a Petition for Review, assailing the CA's findings of negligence on the part of Mejia and Filsyn's lack of due diligence in the selection and supervision of its employee. Filsyn also argued that the damages awarded were not in accordance with the evidence.
Issue(s)
Whether the Court of Appeals erred in finding petitioner's employee, Mejia, negligent. Whether petitioner Filsyn exercised the due diligence of a good father of a family in the selection and supervision of its employees. Whether the damages awarded by the Court of Appeals are in accordance with the evidence on record.
Ruling
The Petition for Review is DENIED. The Decision of the Court of Appeals is AFFIRMED with the MODIFICATION that the moral damages be reduced to ₱50,000.00.
Ratio Decidendi
On the negligence of Mejia: The Court held that the issue of negligence is a question of fact, and it defers to the findings of the RTC and CA, as no exceptions to the rule on factual findings were present. The evidence, including the Police Accident Report and Investigation Report, showed that the shuttle bus was traveling at a reckless speed, exceeding the 50 kph limit under Republic Act No. 4136, and was driving at 70 kph. This excessive speed was the proximate cause of the collision. Furthermore, Mejia violated Section 55 of RA 4136-A by leaving the scene of the accident without aiding the victims or reporting to the authorities. The Court also noted that the petitioner failed to present Mejia as a witness, giving rise to the presumption that his testimony would have been adverse. On Filsyn's exercise of due diligence: The Court reiterated that under Article 2180 of the Civil Code, an employer is presumed negligent if its employee causes injury. The employer bears the burden of proving it exercised the diligence of a good father of a family in selection and supervision. Filsyn's evidence, consisting of Mejia's proficiency and physical examinations, and NBI clearances from ten years prior to the accident, was deemed insufficient. The CA correctly pointed out that Filsyn failed to present proof of rules and regulations governing employee conduct and did not sufficiently explain waiving its policy of hiring high school graduates for Mejia. Moreover, Filsyn failed to show proof of adequate supervision, including ensuring rest periods for drivers working multiple shifts, especially considering the accident occurred late at night. The Court found the evidence wanting to overcome the presumption of negligence. On the damages awarded: The Court affirmed the CA's computation of actual and compensatory damages, finding that respondents established their case by a preponderance of evidence. However, the Court found the award of ₱100,000.00 as moral damages to be excessive, citing jurisprudence that sets the amount at ₱50,000.00. Therefore, the moral damages were reduced accordingly.
Main Doctrine
An employer is vicariously liable for the damages caused by the negligence of its employee under Article 2180 of the Civil Code. To escape liability, the employer must prove it exercised the diligence of a good father of a family in the selection and supervision of its employees. Mere assertion of company policies is insufficient; concrete proof of compliance and monitoring is required. The violation of traffic regulations creates a presumption of negligence, and the employer must overcome this presumption.