Mangaron v. Hanna Via Design & Construction
REITERATIONFacts
The Antecedents: Spouses Emilio and Erlinda Mangaron (petitioners) filed a complaint for damages against Hanna Via Design and Construction (respondent), Power Supply and Equipment Parts, and their driver, Crestino T. Bosquit. The petitioners alleged that Bosquit's negligent driving of an Isuzu Truck owned by Power Supply, but allegedly operated by respondent, caused a collision that resulted in serious physical injuries to the petitioners. The complaint invoked respondent's vicarious liability under Articles 2180 and 2184 of the Civil Code. Procedural History: After the petitioners presented their evidence, respondent filed a demurrer to evidence, questioning the Regional Trial Court's (RTC) jurisdiction and arguing that the complaint was essentially criminal. The RTC denied the demurrer, asserting its jurisdiction over the civil complaint for damages. Respondent then filed a Petition for Certiorari with the Court of Appeals (CA), challenging the RTC's denial of the demurrer. The CA granted the petition, reversing the RTC's orders and dismissing the case, opining that the RTC committed grave abuse of discretion by not applying the registered owner rule, as the vehicle was registered under Power Supply, not the respondent. The Petition: The petitioners filed a Petition for Review on Certiorari with the Supreme Court, assailing the CA's decision. They argued that the CA erred in giving due course to the Petition for Certiorari, as the RTC's order denying the demurrer was interlocutory and not appealable. Furthermore, they contended that the CA erred in setting aside the RTC's order when there was sufficient basis for its denial. The petitioners sought to have the CA's ruling reversed and the RTC's denial of the demurrer reinstated.
Issue(s)
Whether the Court of Appeals erred in giving due course to the Petition for Certiorari filed by respondent. Whether the Regional Trial Court committed grave abuse of discretion in denying the motion for demurrer to evidence.
Ruling
The Petition is denied. The Decision dated October 20, 2015, and the Resolution dated April 14, 2016, of the Court of Appeals in CA-G.R. SP No. 138259 are affirmed in toto.
Ratio Decidendi
On the propriety of the Petition for Certiorari: The Court held that an order denying a demurrer to evidence is an interlocutory order, which generally cannot be subject to an appeal. However, a petition for certiorari under Rule 65 of the Rules of Court is a proper remedy to assail such an order if it is tainted with grave abuse of discretion amounting to lack or excess of jurisdiction. The CA correctly gave due course to the petition as the denial of the demurrer to evidence by the RTC was found to be attended by grave abuse of discretion. On the grave abuse of discretion in denying the demurrer to evidence: The Court agreed with the CA that the RTC committed grave abuse of discretion in denying the demurrer to evidence. The CA correctly applied the registered owner rule, which dictates that the registered owner of a motor vehicle is directly and primarily responsible to the public and third persons for the consequences of its operation, irrespective of who the actual owner or driver might be. In this case, it was undisputed that the registered owner of the subject vehicle was Power Supply, not the respondent Hanna Via Design and Construction. Therefore, the RTC should have considered the application of this rule in evaluating the demurrer to evidence, as it directly pertains to the imputation of liability to the respondent.
Main Doctrine
The denial of a demurrer to evidence may be assailed via a petition for certiorari under Rule 65 of the Rules of Court if tainted with grave abuse of discretion amounting to lack or excess of jurisdiction. The registered owner rule holds the registered owner of a motor vehicle primarily liable to the public and third persons for damages arising from its operation, regardless of the actual ownership.