Greenstar Express v. Universal Robina Corporation
REITERATIONFacts
The Antecedents: On February 25, 2003, a bus owned by petitioner Greenstar Express, Inc. (Greenstar), driven by petitioner Fruto L. Sayson, Jr., collided head-on with a van owned by respondent Universal Robina Corporation (URC) and driven by Renante Bicomong, an Operations Manager of respondent Nissin Universal Robina Corporation (NURC). Bicomong died on the spot. The collision occurred along Maharlika Highway in Alaminos, Laguna. Petitioners filed a complaint for damages against NURC, later amended to include URC, alleging negligence. Procedural History: The Regional Trial Court (RTC) dismissed the complaint and counterclaim, finding that Bicomong was not performing his assigned tasks at the time of the accident, thus absolving URC and NURC from liability under Article 2180 of the Civil Code. The Court of Appeals (CA) affirmed the RTC's decision, reiterating that Bicomong was not acting within the scope of his assigned tasks as the day was a holiday and he was on his way home for personal reasons. The CA also considered the doctrine of last clear chance, suggesting Sayson might have had the opportunity to avoid the collision. The Petition: Petitioners seek to set aside the CA's decision, arguing that respondents should be held liable for Bicomong's negligence, that Bicomong's act of occupying the opposite lane constituted a traffic violation giving rise to a presumption of negligence, and that respondents failed to rebut this presumption. They also contend that respondents' defense of Bicomong not being within the scope of his assigned tasks was not properly pleaded.
Issue(s)
Whether respondents URC and NURC are liable for the damages arising from the vehicular collision caused by the negligence of Renante Bicomong, considering the registered owner rule and Article 2180 of the Civil Code. Whether the defense that Bicomong was not acting within the scope of his assigned tasks was properly raised by the respondents. Whether the doctrine of last clear chance applies in this case, and the extent of negligence attributable to petitioner Sayson.
Ruling
The Supreme Court denied the petition, affirming the decision of the Court of Appeals. The Court held that while URC, as the registered owner, is presumed liable, it successfully overcame this presumption by proving that Bicomong was not acting within the scope of his assigned tasks when the collision occurred. Furthermore, the Court found that petitioner Sayson, the bus driver, had the last clear chance to avoid the accident but failed to exercise the required diligence, thereby contributing to the collision.
Ratio Decidendi
On the issue of respondents' liability under Article 2180 and the registered owner rule: The Court reiterated that the registered owner of a vehicle is presumed liable for damages caused by its operation. This presumption shifts the burden of proof to the owner to demonstrate that no liability under Article 2180 of the Civil Code has arisen. Respondents URC and NURC successfully discharged this burden by presenting evidence that Renante Bicomong was not acting within the scope of his assigned tasks at the time of the collision. The evidence showed that the accident occurred on a national holiday, Bicomong was on his way home for personal reasons, and the vehicle he was driving was not officially assigned to him but was registered to URC and assigned to another employee. Therefore, the employers cannot be held liable for damages caused by Bicomong's actions outside the performance of his duties. On the procedural issue of whether the defense of Bicomong not acting within the scope of his assigned tasks was properly raised: The Court disagreed with petitioners' contention that this defense was not pleaded. It held that while the specific facts illustrating this defense might not have been explicitly stated in the initial pleadings, the respondents presented evidence to this effect during trial. The Court applied Section 5, Rule 10 of the Rules of Court, which allows pleadings to be deemed amended to conform to the evidence presented, especially when no objection was made by the opposing party. Thus, the defense was considered properly raised and considered. On the application of the doctrine of last clear chance: The Court found that petitioner Sayson, the bus driver, had the last clear chance to avoid the collision but failed to exercise the required diligence. Despite observing the URC van traveling precariously on the shoulder and then swerving towards his lane from a considerable distance, Sayson maintained his speed and attempted to swerve only at the last moment, finding it difficult to maneuver. The Court emphasized that as a common carrier, Greenstar Express, Inc. is bound to observe extraordinary diligence for the safety of its passengers. Sayson's failure to slow down, adopt a defensive stance, or take other necessary precautions when he had the opportunity to do so constituted negligence, making him chargeable with the consequences of the collision. His subsequent act of leaving the scene further demonstrated a lack of concern for the victims.
Main Doctrine
The registered owner of a vehicle is presumed liable for damages caused by its operation. This presumption shifts the burden to the owner to prove that no liability under Article 2180 of the Civil Code arose, either by showing no employment relationship, that the employee acted outside the scope of assigned tasks, or that diligence of a good father of a family was exercised. However, the doctrine of last clear chance may still apply, holding the driver with the final opportunity to avoid the accident liable.