Spouses Mangaron v. Hanna Via Design & Construction,
G.R. No. 224186,
September 23, 2019
DOCTRINE: In accordance with the law on compulsory motor vehicle registration, this
Court has consistently ruled that, with respect to the public and third persons, the
registered owner of a motor vehicle is directly and primarily responsible for the
consequences of its operation regardless of who the actual vehicle owner might be.
FACTS: Petitioners filed a complaint for damages under Article 2184 in relation to Article
2180 of the Civil Code against respondents. In said complaint, Sps. Mangaron invoked
respondent's vicarious liability for the negligent driving of their company driver, Crestino
T. Bosquit, of an Isuzu Truck with Plate Number PLM 612, which bumped and dragged
their vehicle, a Ford Ranger Pick-Up with Plate Number XJZ 830. The collision caused
serious physical injuries to petitioners and were confined for a whole month at the Davao
Doctors Hospital in Davao City.
After the petitioners presented their evidence and rested their case, respondent filed a
Motion for Demurrer to Evidence. Respondent questioned the jurisdiction of the RTC over
the case, contending that the complaint is actually a criminal action for reckless
imprudence resulting to physical injuries. Thus, the complaint should have been filed in
Davao City where the vehicular incident happened.
The Regional Trial Court of Malolos denied the motion. The RTC held that the ownership
of the subject vehicle, respondent's working relationship with Bosquit, and its culpability,
are matters of evidence. Moreover, the RTC maintained its jurisdiction over the case as
the case is clearly civil in nature, a complaint for damages.
Respondent filed a Motion for Reconsideration, which was denied. Respondent then filed
a Petition for Certiorari before the Court of Appeals, impugning the jurisdiction of the RTC.
The CA upheld the jurisdiction of the RTC as the complaint spelled out a civil complaint
for damages. However, the CA reversed the ruling of the RTC insofar as the denial of
respondent's demurrer to evidence. It ruled that the RTC committed grave abuse of
discretion and opined that the case should have been dismissed because the registered
owner of the Isuzu Truck is Power Supply, and not the respondent.
Petitioners then filed a Motion for Reconsideration, hence this petition.
ISSUES: Whether or not the RTC committed grave abuse of discretion in denying the
demurrer to evidence.
HELD: Yes. The Court agrees with the CA in finding that the denial of the motion for
demurrer to evidence was tainted with grave abuse of discretion. The CA essentially
found that the RTC failed to consider the application of the registered owner rule. In
accordance with the law on compulsory motor vehicle registration, this Court has
consistently ruled that, with respect to the public and third persons, the registered owner
of a motor vehicle is directly and primarily responsible for the consequences of its
operation regardless of who the actual vehicle owner might be.
On this note, the Court stresses that the registered owner rule is clear and straightforward.
Its rationale is to fix liability on the owner of a motor vehicle involved in an accident by
clear identification through registration. The main aim of motor vehicle registration is to
identify the owner so that if any accident happens, or that any damage or injury is caused
by the vehicle on the public highways, responsibility therefore can be fixed on a definite
individual, the registered owner.
Truly, what the law seeks to prevent is the avoidance of liability in case of accidents to
the detriment of the public. In case an accident occurs, the liability becomes definite and
fixed as against a specific person, so that the victim may be properly indemnified without
having to go through the rigorous and tedious task of trying to identify the owner or driver
of the concerned vehicle.
Thus, the registration of the vehicle's ownership is indispensable in determining
imputation of liability; thus, whoever has his/her name on the Certificate of Registration
of the offending vehicle becomes liable in case of any damage or injury in connection with
the operation of such vehicle inasmuch as the public is concerned.
As between the registered owner and the driver, the former is considered as the employer
of the latter, and is made primarily liable for the tort under Article 2176 in relation with
Article 2180 of the Civil Code.
However, the application of the registered owner rule does not serve as a shield of the
offending vehicle's real owner from any liability. The law is not inequitable. Under the
principle of unjust enrichment, the registered owner who shouldered such liability has a
right to be indemnified by means of a cross-claim as against the actual employer of the
negligent driver. In this way, the preservation of the rights of the parties concerned would
be upheld while championing the public policy behind the registered owner rule.
