G.R. No. 224186 , September 23, 2019
Spouses Emilio Mangaron, Jr. and Erlinda Mangaron, Petitioners, vs. Hanna Via Design & Construction, owned and managed by Engr. James Stephen B. Carpe, Respondent.

FACTS

Petitioners Spouses Mangaron filed a complaint for damages under Articles 2184 and 2180 of the Civil Code against respondent Hanna Via Design & Construction, Power Supply and Equipment Parts (Power Supply), and their driver Crestino T. Bosquit. The complaint alleged that Bosquit, while driving an Isuzu Truck (Plate No. PLM 612), negligently bumped and dragged the petitioners’ vehicle, causing them serious physical injuries. After the petitioners presented their evidence and rested their case, respondent filed a Motion for Demurrer to Evidence, questioning the RTC’s jurisdiction and contending the complaint was a criminal action that should have been filed in Davao City where the incident occurred. The RTC of Malolos City, Branch 11, denied the motion, holding the issues were matters of evidence and that it had jurisdiction as the case was a civil complaint for damages. Respondent’s motion for reconsideration was denied. Respondent then filed a Petition for Certiorari before the CA. The CA upheld the RTC’s jurisdiction but reversed the denial of the demurrer to evidence, ruling the RTC committed grave abuse of discretion because the registered owner of the vehicle was Power Supply, not respondent, and thus the case should be dismissed. Petitioners’ motion for reconsideration was denied.

ISSUE

Whether the Court of Appeals erred in giving due course to the Petition for Certiorari and in setting aside the RTC’s Orders denying the motion for demurrer to evidence.

RULING

The Supreme Court denied the petition and affirmed the CA Decision and Resolution. The Court held that an order denying a demurrer to evidence is an interlocutory order, and while generally not appealable, it may be challenged via a Petition for Certiorari under Rule 65 if tainted with grave abuse of discretion. The Court agreed with the CA that the RTC’s denial was issued with grave abuse of discretion. The Court applied the “registered owner rule,” which holds that for purposes of imputing liability to the public and third persons, the registered owner of a motor vehicle is directly and primarily responsible for consequences arising from its operation, regardless of who the actual owner might be. Since it was undisputed that the registered owner of the vehicle involved was Power Supply and not respondent Hanna Via Design & Construction, the demurrer to evidence should have been granted. The rule aims to fix liability on a definite individual (the registered owner) to ensure victims can be properly indemnified. The registered owner, who is primarily liable, may seek indemnity from the actual employer of the negligent driver through a cross-claim.