GR 98275; (November, 1992) (Digest)
G.R. No. 98275 November 13, 1992
BA FINANCE CORPORATION, petitioner, vs. HON. COURT OF APPEALS, REGIONAL TRIAL COURT OF ANGELES CITY, BRANCH LVI, CARLOS OCAMPO, INOCENCIO TURLA, SPOUSES MOISES AGAPITO and SOCORRO M. AGAPITO and NICOLAS CRUZ, respondents.
FACTS
On March 6, 1983, an accident occurred involving an Isuzu ten-wheeler truck driven by Rogelio Villar y Amare, an employee of Lino Castro. The truck was registered in the name of BA Finance Corporation (petitioner) but was leased to Rock Component Philippines, Inc. at the time of the accident. The driver was found guilty beyond reasonable doubt of reckless imprudence. The victims (private respondents) filed a complaint for damages. The Regional Trial Court held the driver, BA Finance, and Rock Component solidarily liable, ordering BA Finance to pay damages to the plaintiffs and Rock Component to reimburse BA Finance. The Court of Appeals affirmed the decision. BA Finance appealed, arguing it should not be liable as it was not the employer of the driver and the truck was leased to Rock Component.
ISSUE
Whether BA Finance Corporation, as the registered owner of the truck, can be held liable for damages arising from the accident despite the vehicle being leased to another entity at the time and despite the absence of an employer-employee relationship with the negligent driver.
RULING
Yes. The Supreme Court affirmed the decisions of the lower courts, dismissing the petition. The Court held that the registered owner of a vehicle is primarily responsible for damages caused by its operation on public highways, regardless of any lease agreement or transfer. This is based on the policy behind motor vehicle registration laws, which is to identify a financially responsible person to whom the public can look for redress in case of accidents. The registered owner cannot evade this responsibility by proving the vehicle was leased or that the driver was not its employee. The doctrines in Perez vs. Gutierrez and Erezo vs. Jepte were applied, emphasizing that the registered owner is liable to the public, but retains the right to be indemnified by the actual operator or lessee, as stipulated in the lease contract with Rock Component. The exceptions in Duavit vs. Court of Appeals and Duquillo vs. Bayot, where owners were not held liable because the vehicles were used without their consent (e.g., stolen), were deemed inapplicable as the use here was pursuant to a lease agreement.