Nostradamus Villanueva, petitioner, vs. Priscilla R. Domingo and Leandro Luis R. Domingo, respondents.
FACTS
Respondent Priscilla Domingo owned a Mitsubishi Lancer, driven by co-respondent Leandro Domingo. On October 22, 1991, while traversing South Superhighway, their vehicle was struck by another Mitsubishi Lancer, plate number PHK 201 ’91, which darted from Vito Cruz Street. The Domingo vehicle subsequently hit parked cars. The driver of the offending vehicle, Renato Dela Cruz Ocfemia, was found to have an expired license and was positive for alcoholic breath.
The registered owner of the offending vehicle was petitioner Nostradamus Villanueva. Villanueva claimed he was no longer the owner at the time of the accident, having swapped the car with a Pajero owned by Albert Jaucian of Auto Palace Car Exchange. Ocfemia was allegedly an employee of Jaucian. The trial court held Villanueva liable for damages, a decision affirmed by the Court of Appeals, which, however, deleted the award for attorney’s fees.
ISSUE
May the registered owner of a motor vehicle be held liable for damages arising from a vehicular accident involving his vehicle while it is being operated by the employee of its buyer without the latter’s consent and knowledge?
RULING
Yes. The Supreme Court affirmed the liability of the registered owner, Villanueva. The Court reiterated the settled doctrine that the registered owner of any vehicle is directly and primarily responsible to the public and third persons for any damages arising from its operation. This rule is based on public policy and the rationale of the vehicle registration laws, which is to enable the easy identification of the person who can be held accountable for accidents. The public has the right to rely on the registration records, and requiring injured parties to ascertain the actual owner after every private sale would be impractical and prejudicial.
The Court distinguished the case from Duavit v. CA, which involved unauthorized use amounting to theft, a defense not available here. Villanueva voluntarily delivered possession of the car to Jaucian as part of a transaction; thus, he could not claim the vehicle was taken without his consent. The issue of whether Ocfemia was driving with or without the actual owner Jaucian’s authorization is irrelevant in determining the primary liability of the registered owner Villanueva. To allow a registered owner to evade liability by proving a prior sale would defeat the very purpose of the registration system, which is to protect the public. Consequently, Villanueva is primarily liable, though he may seek indemnity from the actual buyer, Jaucian, as ordered by the trial court.
