In the case of Flordeliza Mendoza v. Mutya Soriano, the Supreme Court affirmed the principle that an employer can be held directly liable for damages caused by an employee’s negligence if the employer fails to prove they exercised due diligence in the selection and supervision of that employee. This ruling clarifies that employers cannot simply claim diligence but must provide concrete evidence to support such claims, especially in cases involving vehicular accidents caused by their employees. The decision underscores an employer’s responsibility to ensure their employees’ competence and adherence to traffic laws to protect the public.

When Negligence on the Road Leads to Employer’s Doorstep

The case stems from a tragic incident where Sonny Soriano was fatally hit by a speeding vehicle driven by Lomer Macasasa, an employee of Flordeliza Mendoza. Mutya Soriano, the victim’s wife, along with their minor daughter Julie Ann Soriano, filed a complaint for damages against Macasasa and Mendoza. The central question before the Supreme Court was whether Mendoza, as the employer, could be held liable for Macasasa’s negligence, particularly in light of Article 2180 of the Civil Code, which presumes employer negligence in the selection and supervision of employees.

The petitioner, Mendoza, argued that the Regional Trial Court (RTC) lacked jurisdiction over the case because the amount of damages claimed fell below the jurisdictional threshold of the RTC. Mendoza contended that certain claims, such as moral damages and lost income, should be excluded when determining the jurisdictional amount. However, the Supreme Court clarified that when the claim for damages is the main cause of action, as in cases of quasi-delicts, the entire amount of damages claimed should be considered for jurisdictional purposes. The court cited Administrative Circular No. 09-94, which explicitly states that the exclusion of “damages of whatever kind” applies only when damages are incidental to the main cause of action, not when they constitute the primary claim.

SEC. 19. Jurisdiction in civil cases.–Regional Trial Courts shall exercise exclusive original jurisdiction:

x x x x

(8) In all other cases in which the demand, exclusive of interest, damages of whatever kind, attorney’s fees, litigation expenses, and costs or the value of the property in controversy exceeds One hundred thousand pesos (P100,000.00) or, in such other cases in Metro Manila, where the demand, exclusive of the abovementioned items exceeds Two hundred thousand pesos (P200,000.00).

The Court emphasized that actions for damages based on quasi-delicts are essentially actions for the recovery of a sum of money for tortious acts. The respondents’ claim of P929,006 in damages, along with attorney’s fees, represented the compensation sought for the alleged injury. Therefore, the RTC of Caloocan City rightfully exercised jurisdiction over the case.

Mendoza also argued that because the complaint against Macasasa was dismissed, there was no basis to hold her liable. She further claimed that there was no evidence to prove Macasasa’s negligence. However, the Supreme Court found that Macasasa had violated traffic rules under the Land Transportation and Traffic Code. Specifically, he failed to maintain a safe speed and did not aid Soriano after the accident, violating Section 55 of the Land Transportation and Traffic Code. The court noted that the evidence showed Macasasa was overspeeding, as evidenced by the distance Soriano was thrown and the distance the vehicle traveled before stopping.

Art. 2185. Unless there is proof to the contrary, it is presumed that a person driving a motor vehicle has been negligent if at the time of the mishap, he was violating any traffic regulation.

Under Article 2185 of the Civil Code, a driver violating traffic regulations at the time of an accident is presumed negligent. This presumption, coupled with Macasasa’s actions, established his negligence. The Court also clarified that while respondents could potentially recover damages from Macasasa in a criminal case, Mendoza, as the employer, was directly and separately civilly liable for her failure to exercise due diligence in supervising Macasasa.

Article 2180 of the Civil Code states that employers are liable for damages caused by their employees acting within the scope of their assigned tasks. This liability arises from the presumed negligence of the employer in supervising their employees unless they prove they observed all the diligence of a good father of a family to prevent the damage. In this case, the Supreme Court held Mendoza primarily and solidarily liable because she failed to prove that she exercised the required diligence in supervising Macasasa. The Court noted that Mendoza’s focus on the jurisdictional issue led her to forgo presenting evidence on this crucial point.

Regarding Soriano’s contributory negligence, the Court agreed with the Court of Appeals that Soriano was negligent for not using the pedestrian overpass while crossing Commonwealth Avenue. Consequently, the appellate court appropriately reduced the amount of damages awarded by 20%, based on Article 2179 of the Civil Code, which provides for the mitigation of damages when the plaintiff’s negligence contributes to the injury.

When the plaintiff’s own negligence was the immediate and proximate cause of his injury, he cannot recover damages. But if his negligence was only contributory, the immediate and proximate cause of the injury being the defendant’s lack of due care, the plaintiff may recover damages, but the courts shall mitigate the damages to be awarded.

The ruling reinforces the importance of employers’ responsibility in ensuring their employees are competent and safe drivers, especially when their jobs involve operating vehicles. Employers must actively supervise their employees and take steps to prevent negligence, as they can be held directly liable for the damages caused by their employees’ actions.

FAQs

What was the key issue in this case?	The key issue was whether an employer could be held liable for the damages caused by an employee’s negligence in a vehicular accident, particularly concerning the diligence required in supervising employees.
What is the significance of Article 2180 of the Civil Code?	Article 2180 establishes the liability of employers for damages caused by their employees acting within the scope of their assigned tasks, based on the presumed negligence of the employer in supervision.
What did the court rule about the jurisdiction of the Regional Trial Court (RTC)?	The court ruled that the RTC had jurisdiction because the primary cause of action was the claim for damages, and the total amount of damages claimed exceeded the jurisdictional threshold.
How did the court determine Macasasa’s negligence?	The court determined Macasasa’s negligence based on his violation of traffic rules, including overspeeding and failure to aid the victim after the accident.
What constitutes contributory negligence in this case?	Soriano’s failure to use the pedestrian overpass while crossing the street was considered contributory negligence, leading to a reduction in the damages awarded.
What must an employer do to avoid liability under Article 2180?	To avoid liability, an employer must prove that they exercised the diligence of a good father of a family in the selection and supervision of their employees.
Can an employer be held directly liable even if the employee could also be held liable?	Yes, the employer can be held directly liable for their failure to exercise due diligence in supervising the employee, separate from the employee’s own liability.
What is the practical implication of this ruling for employers?	Employers must prioritize the proper selection, training, and supervision of their employees, especially those operating vehicles, to avoid potential liability for damages caused by their negligence.

This case underscores the importance of employers taking proactive measures to ensure their employees are competent and safe, particularly when their roles involve driving. By implementing comprehensive training programs, conducting regular performance evaluations, and enforcing strict adherence to traffic laws, employers can mitigate the risk of accidents and potential legal liabilities.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: FLORDELIZA MENDOZA, PETITIONER, VS. MUTYA SORIANO, G.R. No. 164012, June 08, 2007