G.R. No. L-53969 February 21, 1989
Purificacion Samala and Leonardo Esguerra, petitioners, vs. Hon. Luis L. Victor, CFI of Cavite, Br. II, Emerita C. Jumanan and Ricardo Jumanan, respondents.

FACTS

On February 7, 1976, respondent Emerita Jumanan was a passenger in a jeepney owned by the Garcia spouses when a collision occurred in Bacoor, Cavite. A Saint Raphael Transit bus, owned by petitioner Purificacion Samala and driven by petitioner Leonardo Esguerra, was running fast and overtaking another vehicle. It violently bumped a delivery panel from behind, causing the panel to swerve into the path of the oncoming jeepney. The collision injured Jumanan, who suffered a fracture and required hospitalization. Jumanan and her husband filed a complaint for damages based on a breach of contract of carriage against the jeepney owners and driver.
The jeepney owners, in their answer, denied negligence and filed a third-party complaint against Samala and Esguerra, alleging the bus driver’s negligence was the proximate cause. Samala and Esguerra, in turn, filed a fourth-party complaint against their insurer. After trial, the Court of First Instance absolved the jeepney defendants of liability. It instead held the third-party defendants (Samala and Esguerra) and their insurer jointly and severally liable to pay damages to the Jumanans.

ISSUE

Whether the trial court erred in holding the third-party defendants (petitioners) directly liable to the original plaintiffs (respondents) on the basis of quasi-delict, despite the plaintiffs’ cause of action being solely for breach of contract against the principal defendants.

RULING

The Supreme Court dismissed the petition and affirmed the trial court’s decision. The Court clarified the nature and function of a third-party complaint under the Rules of Court. A third-party complaint is not merely a claim for contribution or indemnity by a defendant against a third person. It can also be a device for impleading a person who may be directly liable to the plaintiff for the same subject matter, even under a different cause of action. The rule aims to avoid multiplicity of suits and settle all related controversies in a single proceeding.
Here, the jeepney owners’ third-party complaint specifically alleged that the negligence of the bus driver, Esguerra, was the direct and proximate cause of the accident. This properly invoked the scenario where the third party may be directly liable to the plaintiff. Consequently, it was immaterial that the Jumanans’ original complaint was based on contract (culpa contractual) against the jeepney owners, while liability was ultimately adjudged against the bus owner and driver based on tort or quasi-delict (culpa aquiliana). The trial court correctly found the bus driver’s negligence as the cause of the collision. Therefore, petitioners Samala and Esguerra, as employer and employee, were properly held directly liable to the injured passenger, Emerita Jumanan.