G.R. No. 172122, June 22, 2007
MERCURY DRUG CORPORATION and ROLANDO J. DEL ROSARIO, petitioners, vs. SPOUSES RICHARD HUANG and CARMEN HUANG, and STEPHEN HUANG, respondents.

FACTS

On December 20, 1996, a collision occurred on C-5 Highway in Taguig between a car driven by respondent Stephen Huang and a six-wheeler truck owned by petitioner Mercury Drug Corporation and driven by its employee, petitioner Rolando del Rosario. The Huang car was on the left innermost lane, with the Mercury Drug truck on the lane to its right. The truck suddenly swerved left, slamming into the car’s front right side. The impact hurled the car over the island, where it hit a lamppost and landed on the opposite lane. The truck also hit a lamppost and ran over the car. Stephen Huang sustained massive, life-altering injuries resulting in permanent paralysis from the chest down. The car was a total wreck. At the time of the accident, Del Rosario only possessed a Traffic Violation Receipt, as his driver’s license had been confiscated due to a prior apprehension for reckless driving.
The respondents sued for damages, alleging gross negligence by Del Rosario and a failure by Mercury Drug to exercise due diligence in the selection and supervision of its driver. Petitioners countered that Stephen Huang was reckless, claiming his car, from the right lane, bumped the truck’s front tire, causing the accident. The trial court found petitioners jointly and severally liable, awarding substantial damages. The Court of Appeals affirmed the liability but reduced the moral damages award.

ISSUE

Whether the Court of Appeals erred in affirming the finding that petitioner Del Rosario was negligent and that petitioner Mercury Drug is solidarily liable for damages.

RULING

The Supreme Court denied the petition and affirmed the appellate court’s decision. The legal logic rests on the preponderance of evidence establishing petitioner Del Rosario’s negligence as the proximate cause of the accident. The Court found petitioners’ version of events—that the car from the right lane bumped the truck—incredible and physically inconsistent with the evidence. The truck’s significant size and snub-nosed design made it improbable for the lower car to strike its front right tire as claimed. Crucially, the final positions of the vehicles (both on the opposite lane from the car’s original direction) were logically explained only by the truck swerving into the car’s lane, not by the car bumping the truck.
Del Rosario’s act of driving without a valid license, having only a TVR due to a prior offense, further evidenced his disregard for traffic safety. Consequently, Mercury Drug is solidarily liable under Article 2180 of the Civil Code, as the employer failed to rebut the presumption of negligence in the selection and supervision of its driver. The awarded damages, including actual, compensatory for life care and lost earning capacity, moral, and exemplary damages, were upheld as reasonable and proximate results of the quasi-delict. The grant of attorney’s fees was also justified due to the unwarranted act of the petitioners that compelled litigation.