GR 193629; (August, 2011) (Digest)
G.R. No. 193629 ; August 17, 2011
RCJ BUS LINES, INCORPORATED, Petitioner, vs. STANDARD INSURANCE COMPANY, INCORPORATED, Respondent.
FACTS
On June 19, 1994, along the National Highway in Rosario, La Union, a passenger bus owned by RCJ Bus Lines, Inc. (RCJ) and driven by Flor Bola Mangoba (Mangoba) hit a Mitsubishi Lancer from behind. The Mitsubishi Lancer, owned by Rodelene Valentino and insured by Standard Insurance Company, Inc. (Standard), was forced forward and hit a Toyota Corolla in front of it after the Toyota stopped upon seeing a pile of gravel and sand on the road. The Mitsubishi Lancer sustained repair costs of ₱162,151.22, which Standard paid under its comprehensive insurance policy. Standard was subrogated to the rights of the car owner and filed a complaint for damages against Mangoba and RCJ. The Metropolitan Trial Court (MeTC) ruled in favor of Standard, holding Mangoba and RCJ jointly and severally liable. The Regional Trial Court (RTC) affirmed the MeTC decision but deleted the award for exemplary damages. The Court of Appeals affirmed the RTC decision with modification, specifically on the interest rate. RCJ elevated the case to the Supreme Court via a petition for review.
ISSUE
Whether RCJ Bus Lines, Inc., as the registered owner of the bus, is jointly and severally liable with its driver, Flor Bola Mangoba, for the damages arising from the vehicular accident.
RULING
Yes. The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The registered owner of a vehicle is jointly and severally liable with the driver for damages arising from the negligent operation of the vehicle. This liability is based on the principle of respondeat superior under Article 2180 of the Civil Code. An employer may escape liability only by proving that it exercised the diligence of a good father of a family in the selection and supervision of its employees. In this case, RCJ failed to prove such diligence. The testimony of its Operations Manager regarding the requirement for job applicants to submit clearances was deemed insufficient to establish careful selection. Furthermore, evidence showed that the bus was traveling at 60 to 75 kilometers per hour, exceeding the maximum speed limit of 50 kph for buses on an open country road, which constituted a violation of traffic regulations and gave rise to a presumption of negligence. Therefore, RCJ was correctly held jointly and severally liable with its driver for the damages paid by Standard Insurance.