Respondent Jose A. Espinas was driving his car along Leon Guinto Street in Manila. He was already in the middle of the intersection when another car, traversing President Quirino Street and going to Roxas Boulevard, suddenly hit and bumped his car. As a result of the impact, Espinas’ car turned clockwise. The other car escaped from the scene of the incident, but Espinas was able to get its plate number. After verifying with the Land Transportation Office, Espinas learned that the owner of the other car, with plate number UCF-545, is Filcar.
Espinas sent several letters to Filcar and to its President and General Manager Carmen Flor, demanding payment for the damages sustained by his car. Espinas then filed a complaint for damages against Filcar and Carmen Flor before the Metropolitan Trial Court (MeTC) of Manila.
Filcar argued that the car was assigned to its Corporate Secretary Atty. Candido Flor, the husband of Carmen Flor. Atty. Flor, for his part, upon seeing the dent and the crack on the car, allegedly asked Floresca, his personal driver, what happened, and the driver replied that it was a result of a "hit and run" while the car was parked in front of Bogota on Pedro Gil Avenue, Manila.
Filcar denied any liability to Espinas and claimed that the incident was not due to its fault or negligence since Floresca was not its employee but that of Atty. Flor. Filcar and Carmen Flor both said that they always exercised the due diligence required of a good father of a family in leasing or assigning their vehicles to third parties.
The MeTC ruled in favor of Espinas, and ordered Filcar and Carmen Flor, jointly and severally, to pay Espinas for the damages including interest and attorney’s fees.
The Regional Trial Court (RTC) of Manila, in the exercise of its appellate jurisdiction, affirmed the MeTC decision. The RTC ruled that Filcar failed to prove that Floresca was not its employee as no proof was adduced that Floresca was personally hired by Atty. Flor.
On appeal, the CA partly granted the petition; it modified the RTC decision by ruling that Carmen Flor, President and General Manager of Filcar, is not personally liable to Espinas. The appellate court pointed out that, subject to recognized exceptions, the liability of a corporation is not the liability of its corporate officers because a corporate entity – subject to well-recognized exceptions – has a separate and distinct personality from its officers and shareholders. The CA, however, affirmed the liability of Filcar to pay Espinas damages.
Q: Is the Court of Appeals’ decision correct in affirming the liability of Filcar, as registered owner of the motor vehicle, to pay for damages caused to Espinas?
Yes, Court of Appeals’ decision is correct in affirming the liability of Filcar, as registered owner of the motor vehicle, to pay for damages caused to Espinas.
Article 2176. Whoever by act or omission causes damage to another, there being fault or negligence, is obliged to pay for the damage done. Such fault or negligence, if there is no pre-existing contractual relation between the parties, is called a quasi-delict and is governed by the provisions of this Chapter. Under Article 2176, in relation with Article 2180, of the Civil Code, an action predicated on an employee’s act or omission may be instituted against the employer who is held liable for the negligent act or omission committed by his employee. Although the employer is not the actual tortfeasor, the law makes him vicariously liable on the basis of the civil law principle of pater familias for failure to exercise due care and vigilance over the acts of one’s subordinates to prevent damage to another.
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