R Transport v. Yu
REITERATIONFacts
The Antecedents: On December 12, 1993, Loreta J. Yu alighted from a bus and was subsequently hit and run over by another bus driven by Antonio P. Gimena, an employee of R Transport Corporation. Loreta was pronounced dead on arrival at the hospital. Procedural History: Luisito G. Yu, the deceased's husband, filed a complaint for damages against R Transport Corporation, Antonio Gimena, and Metro Manila Transport Corporation (MMTC). MMTC claimed it was merely the registered owner and R Transport was the actual owner and operator. R Transport asserted it exercised due diligence in selecting and supervising its employees and that its buses were in good condition. Gimena was declared in default. The Regional Trial Court (RTC) ruled in favor of Yu, holding R Transport and MMTC primarily and solidarily liable, and Gimena subsidiarily liable, for failing to prove due diligence. The Court of Appeals (CA) affirmed the RTC decision with modification, making Gimena solidarily liable with R Transport, and noted that R Transport's lack of registered ownership did not exculpate it from liability. The CA denied R Transport's motion for reconsideration. The Petition: R Transport filed a petition for review on certiorari, arguing that the CA erred in affirming the RTC's finding of liability, as there was insufficient evidence of its driver's negligence and that it could not be held liable as it was not the registered owner of the bus.
Issue(s)
Whether the Court of Appeals erred in affirming the ruling of the Regional Trial Court finding petitioner R Transport Corporation liable for the damages caused by the negligence of its employee, which was not supported by the evidence on record. Whether R Transport Corporation, as the actual employer and operator but not the registered owner of the bus, can be held solidarily liable for the damages caused by the negligence of its employee.
Ruling
The petition is denied. The Decision and Resolution of the Court of Appeals are affirmed.
Ratio Decidendi
On Issue 1: The Supreme Court disagreed with the petitioner's assertion, reiterating that the question of whether a person is negligent is a question of fact, which is generally beyond the scope of a petition for review on certiorari under Rule 45, as the Court's jurisdiction is limited to reviewing errors of law. The Court found no cogent reason to reverse the consistent findings of both the trial and appellate courts, noting that none of the exceptions to this general rule were present. The records, including testimony and the Autopsy Report, sufficiently demonstrated driver Gimena's negligence, indicating he was running at a reckless speed given the severity of the victim's injuries and the location of the incident, a loading/unloading area in a commercial center. The driver's failure to exercise due diligence by slackening his speed and proceeding cautiously in such a busy area constituted negligence, which was the proximate cause of Loreta J. Yu's death. On Issue 2: The Supreme Court affirmed that R Transport Corporation, as the employer of the negligent driver, is solidarily liable for the damages. Under Article 2180 of the New Civil Code, employers are liable for damages caused by their employees acting within the scope of their assigned tasks, and once employee negligence is established, a presumption arises that the employer was remiss in selection and/or supervision. The petitioner failed to rebut this presumption, as it presented no evidence of due diligence in selecting or supervising driver Gimena, despite ample opportunity. The Court further clarified that the registered owner rule, while holding the registered owner liable, does not exculpate the actual owner or operator. Distinguishing Tamayo v. Aquino, which involved a breach of contract, the Court emphasized that the present case is a tort (quasi-delict) under Article 2176, where the employer's liability is direct and primary. It reaffirmed the long-standing view that for the better protection of the public, both the owner of record and the actual operator should be adjudged jointly and severally liable with the driver, preventing unscrupulous transferees from evading liability.
Main Doctrine
An employer is liable for the damages caused by the negligence of its employee acting within the scope of their assigned tasks. To avoid liability, the employer must rebut the presumption of negligence in selection and supervision by presenting adequate proof of due diligence. The registered owner of a vehicle is not exempt from liability for damages caused by its negligent operation, especially in cases of quasi-delict.