GR L 17459; (September, 1962) (Digest)
G.R. No. L-17459; September 29, 1962
DIWATA VARGAS, petitioner, vs. SALVADOR LANGCAY, CORAZON LANGCAY, HELEN LANGCAY and JOSE AGUAS, respondents.
FACTS
On June 5, 1955, a jeepney hit and injured Corazon and Helen Langcay. The driver, Ramon B. Aguas, was criminally convicted for reckless imprudence. The civil action for damages was separately reserved. Records from the Public Service Commission and Motor Vehicles Office identified Diwata Vargas as the registered owner and operator of the jeepney at the time of the accident. Consequently, the Langcays sued Vargas and the driver for damages.
Vargas defended herself by claiming she had sold the vehicle to Jose B. Aguas, the driver’s father, in August 1953, and that her certificate of public convenience had been cancelled in October 1953. Both the Court of First Instance of Manila and the Court of Appeals held her liable. The CA modified the judgment, holding Vargas only subsidiarily liable under Article 103 of the Revised Penal Code, payable only if the primarily liable driver, Ramon Aguas, was insolvent.
ISSUE
Whether petitioner Diwata Vargas, as the registered owner of the vehicle, is subsidiarily liable under Article 103 of the Revised Penal Code or is directly and primarily liable for damages under civil law principles.
RULING
The Supreme Court ruled that the Court of Appeals erred. Vargas is directly and primarily liable, not merely subsidiarily liable under Article 103 of the Revised Penal Code. The legal logic is anchored on public policy and the protection of the public. Following a line of established precedents, the Court held that the registered owner of a vehicle is directly and primarily responsible to third parties for damages arising from its operation, regardless of any private agreements of sale or transfer.
The Court emphasized that the principle is designed to protect victims who have no means to ascertain the actual owner other than through official registration records. Allowing a registered owner to evade liability by proving a transfer to another would defeat this protective policy and enable collusion to shift responsibility to insolvent parties. Consequently, it is immaterial whether Vargas actually employed the driver or had sold the vehicle; as the registered owner appearing in official records at the time of the accident, her liability is direct and primary. The awarded damages were affirmed as not excessive. The CA decision was modified to impose direct and primary liability on Vargas.