G.R. No. 216569 , June 3, 2019
PHILIPPINE NATIONAL CONSTRUCTION CORPORATION, Petitioner vs. SUPERLINES TRANSPORTATION CO., INC., Respondent

FACTS

This case originated from a 1991 incident where a bus owned by respondent Superlines crashed into petitioner PNCC’s radio room. Upon request of a traffic investigator, Patrolman Cesar Lopera, the bus was towed to PNCC’s compound for safekeeping. PNCC subsequently refused Superlines’s requests to release the bus, demanding payment for the damaged radio room. Superlines filed a complaint for replevin with damages. In a prior Supreme Court ruling ( G.R. No. 169596 ), the Court held that PNCC’s seizure and impoundment of the bus, even upon a police request, constituted an unreasonable seizure. The Court granted Superlines’s prayer for recovery of the bus and remanded the case for the inclusion of indispensable parties, like Lopera, should Superlines pursue its claim for damages.
Upon remand, the bus could not be located. The trial court, after Lopera was dropped as a party, held PNCC and its officer Pedro Balubal solidarily liable. It ordered them to pay Superlines the bus’s value, lost income from 1991-2006, exemplary damages, and attorney’s fees. The Court of Appeals affirmed with modification, reducing the exemplary damages. PNCC appealed, arguing the trial court erred in not holding Lopera liable as directed by the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming PNCC’s liability for damages despite the trial court’s failure to implead the police officer as an indispensable party.

RULING

The Supreme Court denied the petition but modified the awarded damages. The Court clarified that its prior directive to implead Patrolman Lopera as an indispensable party was not mandatory but permissive, to allow a complete resolution of all damage claims. The trial court’s decision to drop Lopera did not absolve PNCC from liability. PNCC’s act of impounding the bus and refusing its release upon Superlines’s demand was an independent, actionable wrong. PNCC acted beyond mere safekeeping and exercised control over the property, making it liable for its subsequent loss.
However, the Court reduced the damages awarded. The award for lost/unearned income was deleted for being speculative and not proven with reasonable certainty. The exemplary damages were reduced from ₱1,000,000 to ₱100,000, as the original amount was excessive compared to jurisprudence for similar violations. Attorney’s fees were also reduced from ₱300,000 to ₱30,000, being more equitable. The award for the bus’s value with interest was sustained as proper compensation for the property PNCC failed to return.