G.R. No. L-50127 March 30, 1979
VICTOR JUANIZA, Heirs of Josefa P. Leus, et al., plaintiffs-appellees, vs. EUGENIO JOSE, THE ECONOMIC INSURANCE COMPANY, INC., and ROSALIA ARROYO, defendants-appellants.

FACTS

Eugenio Jose, the registered owner and operator of a passenger jeepney, figured in a fatal collision with a train on November 23, 1969, resulting in deaths and injuries. At the time, Jose was legally married to Socorro Ramos but had been cohabiting with Rosalia Arroyo for sixteen years in a relationship akin to marriage. In the ensuing civil cases for damages, the Court of First Instance of Laguna held both Eugenio Jose and Rosalia Arroyo jointly and severally liable. The trial court anchored Arroyo’s liability on Article 144 of the Civil Code, ruling that property acquired by a man and woman living together as husband and wife, without marriage, is governed by co-ownership rules, thus making her a co-owner of the jeepney.
Rosalia Arroyo moved for reconsideration, arguing she should not be held liable. Upon denial, she appealed. The Court of Appeals certified the case to the Supreme Court, as the appeal presented purely legal questions.

ISSUE

The primary issue is whether Rosalia Arroyo, who cohabited with the registered vehicle owner but was not married to him due to his existing marriage, can be held jointly and severally liable for damages arising from the vehicle’s operation under the principle of co-ownership in Article 144 of the Civil Code.

RULING

The Supreme Court reversed the trial court’s decision insofar as it held Rosalia Arroyo liable. The legal logic is twofold. First, Article 144 of the Civil Code, which establishes a regime of co-ownership for property acquired by a man and woman living together without marriage, applies only when both parties are legally capacitated to marry each other. Since Eugenio Jose was legally married to another, a legal impediment existed that incapacitated him from contracting a valid marriage with Arroyo. Consequently, the requisite co-ownership under Article 144 cannot arise; the jeepney, acquired during Jose’s marriage, is presumed part of his conjugal partnership with his lawful wife, not a co-ownership with Arroyo.
Second, settled jurisprudence dictates that only the registered owner of a public service vehicle is held responsible for damages arising from its operation. Arroyo was not the registered owner. To hold her liable based on a supposed co-ownership, which the Court found legally non-existent, would have no basis. Therefore, the trial court erred in applying Article 144 to impose joint and several liability. The Supreme Court modified the decision, absolving Rosalia Arroyo from any liability for damages.