GR 153760; (October, 2006) (Digest)
G.R. Nos. 153760-61 ; October 12, 2006
TEODORICO MANZANARES, et al., petitioners, vs. THE PEOPLE OF THE PHILIPPINES, et al., respondents.
FACTS
On January 13, 1983, an Isuzu truck owned by Manhattan Enterprises and driven by Teodorico Manzanares collided with a passenger jeepney along MacArthur Highway in Malolos, Bulacan. The collision resulted in multiple fatalities, including the jeepney driver and several passengers, and caused serious physical injuries to others. The incident spawned several civil cases for damages filed by the victims’ heirs and the injured passengers against Manzanares, Manhattan Enterprises, its managing partner Eduardo Yang, and the jeepney owner, Teodoro Basallo. Concurrently, an Information for Reckless Imprudence Resulting in Multiple Homicide, Damage to Property and Multiple Physical Injuries was filed against Manzanares.
The civil complaints alleged that Manzanares drove the truck in a grossly negligent manner. Petitioners Manhattan Enterprises and Yang were impleaded under the principle of respondeat superior, with claimants asserting their failure to exercise the diligence of a good father of a family in the selection and supervision of their employee, Manzanares. The cases were jointly tried with the criminal case.
ISSUE
The core issue is whether the petitioners, Teodorico Manzanares and his employers (Manhattan Enterprises/Eduardo Yang), are civilly liable for the damages arising from the vehicular collision.
RULING
Yes, petitioners are jointly and severally liable. The Supreme Court affirmed the findings of the lower courts that Manzanares was negligent. Evidence, including the physical evidence at the scene and witness testimonies, established that the Isuzu truck encroached into the lane of the oncoming jeepney, causing the collision. This violation of traffic rules gave rise to the presumption of negligence under Article 2185 of the Civil Code, which petitioners failed to rebut.
Consequently, under Article 2180 of the Civil Code, employers are subsidiarily liable for the damages caused by their employees in the discharge of their duties, provided they acted with negligence. The Court found that Manhattan Enterprises and Eduardo Yang failed to overcome the presumption of negligence in the selection and supervision of Manzanares. They did not present sufficient evidence, such as his driver’s license or proof of training, to demonstrate the requisite diligence. Therefore, the employer’s subsidiary liability is attached. The civil liability arising from the quasi-delict is separate from the criminal liability, and the acquittal in the criminal case (based on reasonable doubt) does not extinguish the civil liability predicated on the preponderance of evidence establishing negligence.