Employers Face Liability for Negligent Acts of Employees

nn

PHILTRANCO SERVICE ENTERPRISES, INC. AND ROGACIONES MANILHIG, PETITIONER, VS. COURT OF APPEALS AND HEIRS OF THE LATE RAMON ACUESTA, RESPONDENTS. G.R. No. 120553, June 17, 1997

nn

Imagine a bustling city street. A bus, struggling to start, is being pushed by eager passengers. Suddenly, the engine roars to life, and the bus lurches forward, tragically hitting a cyclist. Who is responsible? The driver? The bus company? This scenario highlights the complex legal issue of employer liability for the negligent actions of their employees, a critical aspect of Philippine law.

nn

This case, Philtranco Service Enterprises, Inc. vs. Court of Appeals, revolves around a fatal vehicular accident and explores the extent to which an employer is liable for the damages caused by the negligence of its employee. The Supreme Court decision clarifies the principles of quasi-delict and solidary liability, offering valuable insights for businesses and individuals alike.

nn

Understanding Quasi-Delict and Employer Liability

nn

The foundation of this case rests on the concept of quasi-delict, as defined in Article 2176 of the Civil Code of the Philippines:

nn

“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.”

nn

This means that if someone’s negligence causes harm to another, they are legally obligated to compensate for the damages. But what happens when the negligent party is an employee acting within the scope of their employment?

nn

Article 2180 of the Civil Code addresses this, stating that employers are responsible for the damages caused by their employees. This responsibility extends to owners and managers of establishments for damages caused by employees in their service. The law also provides a defense:

nn

“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.”

nn

This “diligence of a good father of a family” refers to the level of care and prudence that a reasonable person would exercise in selecting and supervising their employees.

nn

The Case Unfolds: A Tragedy in Calbayog City

nn

In March 1990, Ramon Acuesta was riding his bicycle in Calbayog City when a Philtranco bus, being pushed to start its engine, suddenly lurched forward and struck him. Acuesta died as a result of the accident. His heirs filed a case against Philtranco and the bus driver, Rogaciones Manilhig, alleging negligence.

nn

The private respondents alleged that the petitioners were guilty of gross negligence, recklessness, violation of traffic rules and regulations, abandonment of victim, and attempt to escape from a crime.

nn

The petitioners, on the other hand, argued that the driver was not negligent and that the victim’s own negligence caused the accident. They claimed that Philtranco exercised due diligence in the selection and supervision of its employees.

nn

The case followed this procedural path:

nn

n
• The Regional Trial Court (RTC) ruled in favor of the heirs, finding both the driver and Philtranco liable.

n

• Philtranco appealed to the Court of Appeals (CA), but the CA affirmed the RTC’s decision.

n

• Philtranco then elevated the case to the Supreme Court.

n

nn

The Supreme Court, in its decision, emphasized the concept of solidary liability, as stated in Article 2194 of the Civil Code:

nn

“The responsibility of two or more persons who are liable for a quasi-delict is solidary.”

nn

This means that the heirs could recover the full amount of damages from either the driver or Philtranco, or from both.

nn

The Court also highlighted the importance of proving negligence, stating:

nn

“…the bumping of the victim was due to appellant Manilhig’s actionable negligence and inattention. Prudence should have dictated against jump-starting the bus in a busy section of the city.”

nn

However, the Supreme Court also found that the lower courts had erred in calculating the amount of damages. The Court reduced the death indemnity, moral damages, exemplary damages, and attorney’s fees, finding them to be excessive.

nn

Practical Implications for Businesses and Individuals

nn

This case serves as a stark reminder to businesses about the importance of due diligence in selecting and supervising employees, especially those operating vehicles or machinery. While the