Filcar Transport Services v. Espinas, G.R. No.

174156, June 20, 2012

Doctrine:
It is well settled that in case of motor vehicle mishaps, the registered owner of the motor vehicle is
considered as the employer of the tortfeasor-driver, and is made primarily liable for the tort
committed by the latter under Article 2176, in relation with Article 2180, of the Civil Code.

In so far as third persons are concerned, the registered owner of the motor vehicle is the employer
of the negligent driver, and the actual employer is considered merely as an agent of such
owner.

Thus, it is clear that for the purpose of holding the registered owner of the motor vehicle primarily and
directly liable for damages under Article 2176, in relation with Article 2180, of the Civil Code, the
existence of an employer-employee relationship, as it is understood in labor relations law, is not
required. It is sufficient to establish that Filcar is the registered owner of the motor vehicle causing
damage in order that it may be held vicariously liable under Article 2180 of the Civil Code.
Facts:
On November 22, 1998, respondent Jose A. Spinas was driving his car, upon reaching an
intersection, at the instance of a green-lit traffic signal; he was hit by another vehicle while
traversing the intersection, hurling his vehicle clockwise. He was able to identify the plate
number UCF-545, and upon checking with the Land Transportation Office, the vehicle was
owned by Filcar Transport Services. Espinas filed an action before the Metropolitan Trial
Court of Manila against Filcar and its President, Mrs. Carmen Flor.

Flor denied liability alleging that the car was driven by the personal driver of her husband,
Timoteo Floresca; alleging further that Floresca was not an employee of Filcar, hence she
should not be held liable as an employer. The MeTC held that Filcar and Carmen Flor shall be
held liable for the damages incurred by Espinas. The Regional Trial Court affirmed the
judgement of the lower court; the Court of Appeals affirmed the decision with modifications,
declaring only Filcar to be exclusively liable for the damages since it has a separate and
distinct personality from that of its corporate owners; hence, this petition for review through
certiorari.
Issues and Holding:
Whether or not Filcar is liable for the damages incurred by Espinas. – YES.

Filcar is vicariously liable for the damages caused by the vehicle registered under its name.
Under the vehicle registration law, the owner of the vehicle will be the one to incur any
liability, treating the identity of the driver at the time of the incident to be trivial and
inconsequential to the proceeding.

Under Article 2176 of the Civil Code, it is contemplated that a person is only liable for the
torts he himself has caused, however, Article 2180 imposes the vicarious liability to employers
of the person who incurred the accident. In this case, it is incorrect for Carmen to allege the
Floresca was not an employee of the company, hence Filcar should not have incurred any
liability; alleging the absence of any employer-employee relationship. It was held in Erezo et
al. vs. Jepte, that the owner of the vehicle shall be held liable for the damage caused by
whoever is the driver of the vehicle at the time; this is to ensure that there will be a definite
identity to whom the accountability shall be imposed upon; as such, any existence of an
employer-employee is irrelevant in this case.

Filcar, as registered owner, is deemed the employer of the driver, Floresca,

and is thus vicariously liable under Article 2176 in relation with Article
2180 of the Civil Code

As a general rule, one is only responsible for his own act or omission.Thus,
a person will generally be held liable only for the torts committed by
himself and not by another. The law, however, provides for exceptions that
an employer is made vicariously liable for the tort committed by his
employee. Article 2180 of the Civil Code states:
Article 2180. The obligation imposed by Article 2176 is demandable not only
for one’s own acts or omissions, but also for those of persons for whom one
is responsible.

Employers shall be liable for the damages caused by their employees and
household helpers acting within the scope of their assigned tasks, even
though the former are not engaged in any business or industry.

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.

It is well settled that in case of motor vehicle mishaps, the registered

owner of the motor vehicle is considered as the employer of the tortfeasor-
driver, and is made primarily liable for the tort committed by the latter
under Article 2176, in relation with Article 2180, of the Civil Code.

Filcar is not be permitted to evade its liability for damages by

conveniently passing on the blame to another party; in this case, its
Corporate Secretary, Atty. Flor and his alleged driver, Floresca.
Dispositive: WHEREFORE, the petition is DENIED. The decision the Court of
Appeals are AFFIRMED. Costs against petitioner Filcar Transport Services.
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Doctrine:

Facts:

Issues and Holding:

Dispositive:

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Facts:

Issues and Holding:

Dispositive:

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Facts:

Issues and Holding:

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Ramos v. Court of Appeals, 321 SCRA 584 (1999) and 380 SCRA 467 (2002)
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Facts:

Issues and Holding:

Dispositive:

Nogales v. Capitol Medical Center, G.R. No. 142625, December 19, 2006
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Facts:

Issues and Holding:

Dispositive:

Professional Services, Inc., v. Agana, 513 SCRA 478 (2007) and G.R. Nos. 126297, 126467, 127590,
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Doctrine:

Facts:

Issues and Holding:

Dispositive:

Casumpang v. Cortejo, G.R. Nos. 171127, 171217 & 17122, March 11, 2015
Doctrine:

Facts:

Issues and Holding:

Dispositive:

Ramos v. COL Realty Corporation, G.R. No. 184905, August 28, 2009
Doctrine:

Facts:

Issues and Holding:

Dispositive: