GR L 11395; (January, 1958) (Digest)
March 11, 2026GR 130637; (August, 1999) (Digest)
March 11, 2026G.R. No. 128705, June 29, 2001
CONRADO AGUILAR, SR., petitioner, vs. COMMERCIAL SAVINGS BANK and FERDINAND BORJA, respondents.
FACTS
Petitioner Conrado Aguilar, Sr. is the father of Conrado Aguilar, Jr., who was killed in a vehicular accident. The accident involved a Lancer car registered in the name of respondent Commercial Savings Bank but driven by co-respondent Ferdinand G. Borja, who was an assistant vice president of the bank. On September 8, 1984, the Lancer, while overtaking a jeepney, hit Aguilar, Jr. and a companion as they crossed the road. Aguilar, Jr. was pronounced dead on arrival. Petitioner filed a complaint for damages. The trial court held both respondents jointly and severally liable, finding Borja negligent and the bank liable under Article 2180 of the Civil Code. The Court of Appeals reversed the decision as to the bank, dismissing the complaint against it. The appellate court found no evidence that Borja was acting within the scope of his functions for the bank at the time of the accident. The bank also argued that Borja had already bought the car on installment, so it was no longer the owner.
ISSUE
Whether or not respondent bank, as the registered owner of the vehicle involved in the accident, is liable for damages.
RULING
Yes. The Supreme Court granted the petition and reinstated the trial court’s decision, holding the bank liable. The Court ruled that the registered owner of any vehicle is primarily responsible to third parties for deaths, injuries, and damages caused by the vehicle, even in the absence of an employer-employee relationship with the driver at the time of the incident. This is based on the policy behind motor vehicle registration, which is to identify a responsible party in case of accidents on public highways. The bank’s defenses—that Borja was not performing his official functions and that he had already purchased the car—were immaterial. As long as the bank remained the registered owner, it could not escape primary liability. The Court of Appeals erred in requiring proof that Borja was acting within his functions and in considering the alleged sale.