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html

G.R. No. 174156. June 20, 2012.*

FILCAR TRANSPORT SERVICES, petitioner, vs. JOSE A.
ESPINAS, respondent.

Civil Law; Quasi-Delicts; A person will generally be held

liable only for the torts committed by himself and not by another.—
As a general rule, one is only responsible for his own act or
omission. Thus, a person will generally be held liable only for the
torts committed by himself and not by another. This general rule
is laid down in Article 2176 of the Civil Code, which provides to
wit: Article 2176. Whoever by act or omission causes damage to
another, there being fault or negligence, is obliged to pay for the
damage done. Such fault or negligence, if there is no pre-existing
contractual relation between

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* SECOND DIVISION.

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the parties, is called a quasi-delict and is governed by the

provisions of this Chapter. Based on the above-cited article, the
obligation to indemnify another for damage caused by one’s act or
omission is imposed upon the tortfeasor himself, i.e., the person
who committed the negligent act or omission. The law, however,
provides for exceptions when it makes certain persons liable for
the act or omission of another.
Same; Same; Vicarious Liability; Under Article 2176, in
relation with Article 2180, of the Civil Code, an action predicated
on an employee’s act or omission may be instituted against the
employer who is held liable for the negligent act or omission
committed by his employee.—Under Article 2176, in relation with
Article 2180, of the Civil Code, an action predicated on an
employee’s act or omission may be instituted against the employer
who is held liable for the negligent act or omission committed by

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his employee. Although the employer is not the actual tortfeasor,

the law makes him vicariously liable on the basis of the civil law
principle of pater familias for failure to exercise due care and
vigilance over the acts of one’s subordinates to prevent damage to
another. In the last paragraph of Article 2180 of the Civil Code,
the employer may invoke the defense that he observed all the
diligence of a good father of a family to prevent damage.
Same; Same; Same; Motor Vehicles; In case of motor vehicle
mishaps, the registered owner of the motor vehicle is considered as
the employer of the tortfeasor-driver, and is made primarily liable
for the tort committed by the latter under Article 2176, in relation
with Article 2180, of the Civil Code.—It is well settled that in case
of motor vehicle mishaps, the registered owner of the motor
vehicle is considered as the employer of the tortfeasor-
driver, and is made primarily liable for the tort committed by the
latter under Article 2176, in relation with Article 2180, of the
Civil Code. In Equitable Leasing Corporation v. Suyom, 388 SCRA
445 (2002), we ruled that in so far as third persons are concerned,
the registered owner of the motor vehicle is the employer
of the negligent driver, and the actual employer is
considered merely as an agent of such owner.

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Same; Same; Same; Same; In contemplation of law, the owner/

operator of record is the employer of the driver, the actual operator
and employer being considered as merely its agent.—In upholding
the liability of Equitable, as registered owner of the tractor, this
Court said that “regardless of sales made of a motor vehicle, the
registered owner is the lawful operator insofar as the public and
third persons are concerned; consequently, it is directly and
primarily responsible for the consequences of its operation.” The
Court further stated that “[i]n contemplation of law, the
owner/operator of record is the employer of the driver, the
actual operator and employer being considered as merely
its agent.” Thus, Equitable, as the registered owner of the
tractor, was considered under the law on quasi delict to be the
employer of the driver, Raul Tutor; Ecatine, Tutor’s actual
employer, was deemed merely as an agent of Equitable. Thus, it is
clear that for the purpose of holding the registered owner of the
motor vehicle primarily and directly liable for damages under
Article 2176, in relation with Article 2180, of the Civil Code, the
existence of an employer-employee relationship, as it is

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understood in labor relations law, is not required. It is sufficient

to establish that Filcar is the registered owner of the motor
vehicle causing damage in order that it may be held vicariously
liable under Article 2180 of the Civil Code.
Same; Same; Same; Same; Whether there is an employer-
employee relationship between the registered owner and the driver
is irrelevant in determining the liability of the registered owner
who the law holds primarily and directly responsible for any
accident, injury or death caused by the operation of the vehicle in
the streets and highways.—The rationale for the rule that a
registered owner is vicariously liable for damages caused by the
operation of his motor vehicle is explained by the principle behind
motor vehicle registration, which has been discussed by this Court
in Erezo, and cited by the CA in its decision: The main aim of
motor vehicle registration is to identify the owner so that
if any accident happens, or that any damage or injury is
caused by the vehicle on the public highways,
responsibility therefor can be fixed on a definite
individual, the registered owner. Instances are numerous
where vehicles running on public highways caused accidents or
injuries to pedestrians or other vehicles without positive
identification of the owner or drivers, or with very scant means of
identification. It is to forestall these circumstances, so
inconvenient or preju-

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dicial to the public, that the motor vehicle registration is

primarily ordained, in the interest of the determination of persons
responsible for damages or injuries caused on public highways.
[emphasis ours] Thus, whether there is an employer-employee
relationship between the registered owner and the driver is
irrelevant in determining the liability of the registered owner who
the law holds primarily and directly responsible for any accident,
injury or death caused by the operation of the vehicle in the
streets and highways.
Same; Same; Same; Same; The general public policy involved
in motor vehicle registration is the protection of innocent third
persons who may have no means of identifying public road
malefactors.—As explained by this Court in Erezo, the general
public policy involved in motor vehicle registration is the
protection of innocent third persons who may have no means of

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identifying public road malefactors and, therefore, would find it

difficult—if not impossible—to seek redress for damages they may
sustain in accidents resulting in deaths, injuries and other
damages; by fixing the person held primarily and directly liable
for the damages sustained by victims of road mishaps, the law
ensures that relief will always be available to them.
Same; Same; Same; Same; To identify the person primarily
and directly responsible for the damages would also prevent a
situation where a registered owner of a motor vehicle can easily
escape liability by passing on the blame to another who may have
no means to answer for the damages caused, thereby defeating the
claims of victims of road accidents.—To identify the person
primarily and directly responsible for the damages would also
prevent a situation where a registered owner of a motor vehicle
can easily escape liability by passing on the blame to another who
may have no means to answer for the damages caused, thereby
defeating the claims of victims of road accidents. We take note
that some motor vehicles running on our roads are driven not by
their registered owners, but by employed drivers who, in most
instances, do not have the financial means to pay for the damages
caused in case of accidents.
Same; Same; Same; Same; The motor vehicle registration law,
to a certain extent, modified Article 2180 of the Civil Code by
making these defenses (that the employee acts beyond the scope of
his assigned task or that it exercised the due diligence of a good
father of a family

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to prevent damage) unavailable to the registered owner of the

motor vehicle.—Filcar should not be permitted to evade its
liability for damages by conveniently passing on the blame to
another party; in this case, its Corporate Secretary, Atty. Flor and
his alleged driver, Floresca. Following our reasoning in Equitable,
the agreement between Filcar and Atty. Flor to assign the motor
vehicle to the latter does not bind Espinas who was not a party to
and has no knowledge of the agreement, and whose only recourse
is to the motor vehicle registration. Neither can Filcar use the
defenses available under Article 2180 of the Civil Code—that the
employee acts beyond the scope of his assigned task or that it
exercised the due diligence of a good father of a family to prevent
damage—because the motor vehicle registration law, to a certain

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extent, modified Article 2180 of the Civil Code by making these

defenses unavailable to the registered owner of the motor vehicle.
Thus, for as long as Filcar is the registered owner of the car
involved in the vehicular accident, it could not escape primary
liability for the damages caused to Espinas.
Same; Same; Same; Same; Road safety is one of the most
common problems that must be addressed in this country.—The
public interest involved in this case must not be underestimated.
Road safety is one of the most common problems that must be
addressed in this country. We are not unaware of news of road
accidents involving reckless drivers victimizing our citizens. Just
recently, such pervasive recklessness among most drivers took the
life of a professor of our state university. What is most disturbing
is that our existing laws do not seem to deter these road
malefactors from committing acts of recklessness.
Same; Same; Same; Same; Whether the driver of the motor
vehicle, Floresca, is an employee of Filcar is irrelevant in arriving
at the conclusion that Filcar is primarily and directly liable for the
damages sustained by Espinas.—Whether the driver of the motor
vehicle, Floresca, is an employee of Filcar is irrelevant in arriving
at the conclusion that Filcar is primarily and directly liable for
the damages sustained by Espinas. While Republic Act No. 4136
or the Land Transportation and Traffic Code does not contain any
provision on the liability of registered owners in case of motor
vehicle mishaps, Article 2176, in relation with Article 2180, of the
Civil Code imposes an obligation upon Filcar, as registered owner,
to answer for the damages caused to Espinas’ car. This
interpretation is consistent

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with the strong public policy of maintaining road safety, thereby

reinforcing the aim of the State to promote the responsible
operation of motor vehicles by its citizens.
Same; Same; Same; Same; Unjust Enrichment; Under the
civil law principle of unjust enrichment, the registered owner of the
motor vehicle has a right to be indemnified by the actual employer
of the driver of the amount that he may be required to pay as
damages for the injury caused to another.—Under the civil law
principle of unjust enrichment, the registered owner of the motor
vehicle has a right to be indemnified by the actual employer of the
driver of the amount that he may be required to pay as damages

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for the injury caused to another.

PETITION for review on certiorari of the decision and

resolution of the Court of Appeals.
   The facts are stated in the opinion of the Court.
  Ferdinand M. Jose for petitioner.
  The Law Firm of Espinas & Associates for respondent.

BRION, J.:
We resolve the present petition for review on certiorari1
filed by petitioner Filcar Transport Services (Filcar),
challenging the decision2 and the resolution3 of the Court of
Appeals (CA) in CA-G.R. SP No. 86603.
The facts of the case, gathered from the records, are
briefly summarized below.

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1 Filed under Rule 45 of the Revised Rules of Court; Rollo,
pp. 10-19.
2 Dated February 16, 2006; penned by Associate Justice Rosalinda
Asuncion-Vicente, and concurred in by Associate Justices Edgardo P. Cruz
and Sesinando E. Villon. Id., at pp. 21-28.
3 Dated July 6, 2006, id., at pp. 30-31.

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On November 22, 1998, at around 6:30 p.m., respondent

Jose A. Espinas was driving his car along Leon Guinto
Street in Manila. Upon reaching the intersection of Leon
Guinto and President Quirino Streets, Espinas stopped his
car. When the signal light turned green, he proceeded to
cross the intersection. He was already in the middle of the
intersection when another car, traversing President
Quirino Street and going to Roxas Boulevard, suddenly hit
and bumped his car. As a result of the impact, Espinas’ car
turned clockwise. The other car escaped from the scene of
the incident, but Espinas was able to get its plate number.
After verifying with the Land Transportation Office,
Espinas learned that the owner of the other car, with plate
number UCF-545, is Filcar.
Espinas sent several letters to Filcar and to its
President and General Manager Carmen Flor, demanding
payment for the damages sustained by his car. On May 31,
2001, Espinas filed a complaint for damages against Filcar

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and Carmen Flor before the Metropolitan Trial Court

(MeTC) of Manila, and the case was raffled to Branch 13.
In the complaint, Espinas demanded that Filcar and
Carmen Flor pay the amount of P97,910.00, representing
actual damages sustained by his car.
Filcar argued that while it is the registered owner of the
car that hit and bumped Espinas’ car, the car was assigned
to its Corporate Secretary Atty. Candido Flor, the husband
of Carmen Flor. Filcar further stated that when the
incident happened, the car was being driven by Atty. Flor’s
personal driver, Timoteo Floresca.
Atty. Flor, for his part, alleged that when the incident
occurred, he was attending a birthday celebration at a
nearby hotel, and it was only later that night when he
noticed a small dent on and the cracked signal light of the
car. On seeing the dent and the crack, Atty. Flor allegedly
asked Floresca what happened, and the driver replied that
it was a result of a “hit
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and run” while the car was parked in front of Bogota on

Pedro Gil Avenue, Manila.
Filcar denied any liability to Espinas and claimed that
the incident was not due to its fault or negligence since
Floresca was not its employee but that of Atty. Flor. Filcar
and Carmen Flor both said that they always exercised the
due diligence required of a good father of a family in
leasing or assigning their vehicles to third parties.
The MeTC Decision
The MeTC, in its decision dated January 20, 2004,4
ruled in favor of Espinas, and ordered Filcar and Carmen
Flor, jointly and severally, to pay Espinas P97,910.00 as
actual damages, representing the cost of repair, with
interest at 6% per annum from the date the complaint was
filed; P50,000.00 as moral damages; P20,000.00 as
exemplary damages; and P20,000.00 as attorney’s fees. The
MeTC ruled that Filcar, as the registered owner of the
vehicle, is primarily responsible for damages resulting from
the vehicle’s operation.
The RTC Decision
The Regional Trial Court (RTC) of Manila, Branch 20, in
the exercise of its appellate jurisdiction, affirmed the MeTC
decision.5 The RTC ruled that Filcar failed to prove that

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Floresca was not its employee as no proof was adduced that

Floresca was personally hired by Atty. Flor. The RTC
agreed with the MeTC that the registered owner of a
vehicle is directly and primarily liable for the damages
sustained by third persons as a consequence of the
negligent or careless operation of a vehicle registered in its
name. The RTC added that the victim of recklessness on
the public highways is without means to discover or
identify the person actually causing the

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4 Id., at pp. 71-78.
5 Id., at pp. 52-57.

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injury or damage. Thus, the only recourse is to determine

the owner, through the vehicle’s registration, and to hold
him responsible for the damages.
The CA Decision
On appeal, the CA partly granted the petition in CA-
G.R. SP No. 86603; it modified the RTC decision by ruling
that Carmen Flor, President and General Manager of
Filcar, is not personally liable to Espinas. The appellate
court pointed out that, subject to recognized exceptions, the
liability of a corporation is not the liability of its corporate
officers because a corporate entity—subject to well-
recognized exceptions—has a separate and distinct
personality from its officers and shareholders. Since the
circumstances in the case at bar do not fall under the
exceptions recognized by law, the CA concluded that the
liability for damages cannot attach to Carmen Flor.
The CA, however, affirmed the liability of Filcar to pay
Espinas damages. According to the CA, even assuming that
there had been no employer-employee relationship between
Filcar and the driver of the vehicle, Floresca, the former
can be held liable under the registered owner rule.
The CA relied on the rule that the registered owner of a
vehicle is directly and primarily responsible to the public
and to third persons while the vehicle is being operated.
Citing Erezo, et al. v. Jepte,6 the CA said that the rationale
behind the rule is to avoid circumstances where vehicles
running on public highways cause accidents or injuries to
pedestrians or other vehicles without positive identification

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of the owner or drivers, or with very scant means of

identification. In Erezo, the Court said that the main aim of
motor vehicle registration is to identify the owner, so that if
a vehicle causes damage or injury to pedestrians or other
vehicles, responsibility can be

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6 102 Phil. 103 (1957).

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traced to a definite individual and that individual is the

registered owner of the vehicle.7
The CA did not accept Filcar’s argument that it cannot
be held liable for damages because the driver of the vehicle
was not its employee. In so ruling, the CA cited the case of
Villanueva v. Domingo8 where the Court said that the
question of whether the driver was authorized by the
actual owner is irrelevant in determining the primary and
direct responsibility of the registered owner of a vehicle for
accidents, injuries and deaths caused by the operation of
his vehicle.
Filcar filed a motion for reconsideration which the CA
denied in its Resolution dated July 6, 2006.
Hence, the present petition.

The Issue

Simply stated, the issue for the consideration of this

Court is: whether Filcar, as registered owner of the motor
vehicle which figured in an accident, may be held liable for
the damages caused to Espinas.
Our Ruling
The petition is without merit.
Filcar, as registered owner, is
deemed the employer of the driver,
Floresca, and is thus vicariously
liable under Article 2176 in relation
with Article 2180 of the Civil Code
It is undisputed that Filcar is the registered owner of
the motor vehicle which hit and caused damage to Espinas’
car;

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7 Id., at p. 108.
8 481 Phil. 837, 851; 438 SCRA 485, 492 (2004).

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and it is on the basis of this fact that we hold Filcar

primarily and directly liable to Espinas for damages.
As a general rule, one is only responsible for his own act
or omission.9 Thus, a person will generally be held liable
only for the torts committed by himself and not by another.
This general rule is laid down in Article 2176 of the Civil
Code, which provides to wit:

“Article 2176. Whoever by act or omission causes damage to

another, there being fault or negligence, is obliged to pay for the
damage done. Such fault or negligence, if there is no pre-existing
contractual relation between the parties, is called a quasi-delict
and is governed by the provisions of this Chapter.”

Based on the above-cited article, the obligation to

indemnify another for damage caused by one’s act or
omission is imposed upon the tortfeasor himself, i.e., the
person who committed the negligent act or omission. The
law, however, provides for exceptions when it makes
certain persons liable for the act or omission of another.
One exception is an employer who is made vicariously
liable for the tort committed by his employee. Article 2180
of the Civil Code states:

“Article 2180. The obligation imposed by Article 2176 is

demandable not only for one’s own acts or omissions, but also for
those of persons for whom one is responsible.
x x x x
Employers shall be liable for the damages caused by their
employees and household helpers acting within the scope of their
assigned tasks, even though the former are not engaged in any
business or industry.
x x x x

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9 Hector S. de Leon and Hector M. de Leon, Jr., Comments and Cases on Torts
and Damages (2004), p. 329. 

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The responsibility treated of in this article shall cease when the
persons herein mentioned prove that they observed all the
diligence of a good father of a family to prevent damage.”

Under Article 2176, in relation with Article 2180, of the

Civil Code, an action predicated on an employee’s act or
omission may be instituted against the employer who is
held liable for the negligent act or omission committed by
his employee.
Although the employer is not the actual tortfeasor, the
law makes him vicariously liable on the basis of the civil
law principle of pater familias for failure to exercise due
care and vigilance over the acts of one’s subordinates to
prevent damage to another.10 In the last paragraph of
Article 2180 of the Civil Code, the employer may invoke the
defense that he observed all the diligence of a good father of
a family to prevent damage.
As its core defense, Filcar contends that Article 2176, in
relation with Article 2180, of the Civil Code is inapplicable
because it presupposes the existence of an employer-
employee relationship. According to Filcar, it cannot be
held liable under the subject provisions because the driver
of its vehicle at the time of the accident, Floresca, is not its
employee but that of its Corporate Secretary, Atty. Flor.
We cannot agree. It is well settled that in case of motor
vehicle mishaps, the registered owner of the motor
vehicle is considered as the employer of the
tortfeasor-driver, and is made primarily liable for the
tort committed by the latter under Article 2176, in relation
with Article 2180, of the Civil Code.
In Equitable Leasing Corporation v. Suyom,11 we ruled
that in so far as third persons are concerned, the
registered owner of the motor vehicle is the
employer of the neg-

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10   Id., at p. 330.
11 437 Phil. 244, 252; 388 SCRA 445, 453-454 (2002).

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ligent driver, and the actual employer is considered

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merely as an agent of such owner.

In that case, a tractor registered in the name of
Equitable Leasing Corporation (Equitable) figured in an
accident, killing and seriously injuring several persons. As
part of its defense, Equitable claimed that the tractor was
initially leased to Mr. Edwin Lim under a Lease
Agreement, which agreement has been overtaken by a
Deed of Sale entered into by Equitable and Ecatine
Corporation (Ecatine). Equitable argued that it cannot be
held liable for damages because the tractor had already
been sold to Ecatine at the time of the accident and the
negligent driver was not its employee but of Ecatine.
In upholding the liability of Equitable, as registered
owner of the tractor, this Court said that “regardless of
sales made of a motor vehicle, the registered owner is the
lawful operator insofar as the public and third persons are
concerned; consequently, it is directly and primarily
responsible for the consequences of its operation.”12 The
Court further stated that “[i]n contemplation of law,
the owner/operator of record is the employer of the
driver, the actual operator and employer being
considered as merely its agent.”13 Thus, Equitable, as
the registered owner of the tractor, was considered under
the law on quasi delict to be the employer of the driver,
Raul Tutor; Ecatine, Tutor’s actual employer, was deemed
merely as an agent of Equitable.
Thus, it is clear that for the purpose of holding the
registered owner of the motor vehicle primarily and directly
liable for damages under Article 2176, in relation with
Article 2180, of the Civil Code, the existence of an
employer-employee relationship, as it is understood in
labor relations law, is not required. It is sufficient to
establish that Filcar is the registered owner of the motor
vehicle causing damage in order that it

_______________
12 Id., at p. 255; p. 453.
13 Ibid.

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may be held vicariously liable under Article 2180 of the

Civil Code.
Rationale for holding the registered

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 owner vicariously liable

The rationale for the rule that a registered owner is
vicariously liable for damages caused by the operation of
his motor vehicle is explained by the principle behind motor
vehicle registration, which has been discussed by this
Court in Erezo, and cited by the CA in its decision:

The main aim of motor vehicle registration is to identify

the owner so that if any accident happens, or that any
damage or injury is caused by the vehicle on the public
highways, responsibility therefor can be fixed on a definite
individual, the registered owner. Instances are numerous
where vehicles running on public highways caused accidents or
injuries to pedestrians or other vehicles without positive
identification of the owner or drivers, or with very scant means of
identification. It is to forestall these circumstances, so
inconvenient or prejudicial to the public, that the motor vehicle
registration is primarily ordained, in the interest of the
determination of persons responsible for damages or injuries
caused on public highways. [emphasis ours]

Thus, whether there is an employer-employee

relationship between the registered owner and the driver is
irrelevant in determining the liability of the registered
owner who the law holds primarily and directly responsible
for any accident, injury or death caused by the operation of
the vehicle in the streets and highways.
As explained by this Court in Erezo, the general public
policy involved in motor vehicle registration is the
protection of innocent third persons who may have no
means of identifying public road malefactors and, therefore,
would find it difficult—if not impossible—to seek redress
for damages they may sustain in accidents resulting in
deaths, injuries and other damages; by fixing the person
held primarily and directly
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liable for the damages sustained by victims of road

mishaps, the law ensures that relief will always be
available to them.
To identify the person primarily and directly responsible
for the damages would also prevent a situation where a
registered owner of a motor vehicle can easily escape
liability by passing on the blame to another who may have

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no means to answer for the damages caused, thereby

defeating the claims of victims of road accidents. We take
note that some motor vehicles running on our roads are
driven not by their registered owners, but by employed
drivers who, in most instances, do not have the financial
means to pay for the damages caused in case of accidents.
These same principles apply by analogy to the case at
bar. Filcar should not be permitted to evade its liability for
damages by conveniently passing on the blame to another
party; in this case, its Corporate Secretary, Atty. Flor and
his alleged driver, Floresca. Following our reasoning in
Equitable, the agreement between Filcar and Atty. Flor to
assign the motor vehicle to the latter does not bind Espinas
who was not a party to and has no knowledge of the
agreement, and whose only recourse is to the motor vehicle
registration.
Neither can Filcar use the defenses available under
Article 2180 of the Civil Code—that the employee acts
beyond the scope of his assigned task or that it exercised
the due diligence of a good father of a family to prevent
damage—because the motor vehicle registration law, to a
certain extent, modified Article 2180 of the Civil Code by
making these defenses unavailable to the registered owner
of the motor vehicle. Thus, for as long as Filcar is the
registered owner of the car involved in the vehicular
accident, it could not escape primary liability for the
damages caused to Espinas.
The public interest involved in this case must not be
underestimated. Road safety is one of the most common
problems that must be addressed in this country. We are
not unaware of news of road accidents involving reckless
drivers victimizing our citizens. Just recently, such
pervasive reck-
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Filcar Transport Services vs. Espinas

lessness among most drivers took the life of a professor of

our state university.14 What is most disturbing is that our
existing laws do not seem to deter these road malefactors
from committing acts of recklessness.
We understand that the solution to the problem does not
stop with legislation. An effective administration and
enforcement of the laws must be ensured to reinforce
discipline among drivers and to remind owners of motor

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vehicles to exercise due diligence and vigilance over the

acts of their drivers to prevent damage to others.
Thus, whether the driver of the motor vehicle, Floresca,
is an employee of Filcar is irrelevant in arriving at the
conclusion that Filcar is primarily and directly liable for
the damages sustained by Espinas. While Republic Act No.
4136 or the Land Transportation and Traffic Code does not
contain any provision on the liability of registered owners
in case of motor vehicle mishaps, Article 2176, in relation
with Article 2180, of the Civil Code imposes an obligation
upon Filcar, as registered owner, to answer for the
damages caused to Espinas’ car. This interpretation is
consistent with the strong public policy of maintaining road
safety, thereby reinforcing the aim of the State to promote
the responsible operation of motor vehicles by its citizens.
This does not mean, however, that Filcar is left without
any recourse against the actual employer of the driver and
the driver himself. Under the civil law principle of unjust
enrichment, the registered owner of the motor vehicle has a
right to be indemnified by the actual employer of the driver
of the amount that he may be required to pay as damages
for the injury caused to another.

_______________
14 Veteran journalist-professor dies in vehicular accident on “killer
highway” http://newsinfo.inquirer.net/breakingnews/metro
/view/20110513-336347/Veteran-journalist-professor-dies-in-vehicular-
accident-on-killer-highway.

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Filcar Transport Services vs. Espinas

The set-up may be inconvenient for the registered owner

of the motor vehicle, but the inconvenience cannot
outweigh the more important public policy being advanced
by the law in this case which is the protection of innocent
persons who may be victims of reckless drivers and
irresponsible motor vehicle owners.
WHEREFORE, the petition is DENIED. The decision
dated February 16, 2006 and the resolution dated July 6,
2006 of the Court of Appeals are AFFIRMED. Costs against
petitioner Filcar Transport Services.
SO ORDERED.

Carpio (Chairperson), Perez, Sereno and Reyes, JJ.,

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concur. 

Petition denied, judgment affirmed.

Notes.—Unless there is proof to the contrary, a person

driving a vehicle is presumed negligent if at the time of the
mishap, he was violating any traffic regulation. (Guillang
vs. Bedania, 588 SCRA 73 [2009])
U-turns are generally not advisable particularly on
major streets. (Id.)
Under Article 2180 of the New Civil Code, when an
injury is caused by the negligence of the employee, there
instantly arises a presumption of law that there was
negligence on the part of the master or employer either in
the selection of the servant or employee, or in supervision
over him after selection or both. (Filipinas Synthetic Fiber
Corporation vs. De los Santos, 645 SCRA 463 [2011])
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