The Supreme Court has clarified the burden of proof in cases involving an employer’s liability for the negligent acts of their employees. The Court ruled that once a plaintiff proves an employee’s negligence occurred within the scope of their assigned tasks, the burden shifts to the employer to prove they exercised due diligence in selecting and supervising the employee. Failing to do so results in the employer being held solidarily liable for damages. This decision emphasizes the importance of employers actively demonstrating their commitment to ensuring their employees act responsibly and avoid negligence.

Who’s Responsible? When a Driver’s Negligence Leads to Employer’s Liability

In Raul S. Imperial v. Heirs of Neil Bayaban, and Mary Lou Bayaban, the central issue revolved around determining the extent of an employer’s liability for the negligent actions of their employee. On December 14, 2003, a van owned by Raul S. Imperial and driven by his employee, William Laraga, was involved in an accident with a tricycle, resulting in severe injuries to spouses Neil and Mary Lou Bayaban. The Bayaban Spouses sought compensation for their injuries, leading to a legal battle that reached the Supreme Court.

The case hinged on Articles 2176 and 2180 of the Civil Code, which address quasi-delicts and vicarious liability. Article 2176 defines quasi-delict as fault or negligence causing damage to another in the absence of a pre-existing contractual relationship. Article 2180 extends this liability, holding employers responsible for the damages caused by their employees acting within the scope of their assigned tasks, even if the employer is not engaged in any business or industry. This responsibility ceases only when the employer proves they exercised the diligence of a good father of a family to prevent the damage.

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. 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.

The legal principle of vicarious liability, as explained in Cangco v. Manila Railroad Co., imposes moral responsibility on employers for the negligence of their employees. However, this responsibility is limited to instances where the employee acts within the scope of their assigned tasks. An act is considered within the scope of employment if it is done by an employee in furtherance of the interests of the employer or for the account of the employer at the time of the injury or damage.

The Supreme Court, in this case, determined that the Bayaban Spouses successfully demonstrated that Laraga was acting within the scope of his employment at the time of the accident. The accident occurred at 3:00 p.m. in Antipolo City, where Imperial’s greenhouse and garden were located. This supported the conclusion that Laraga was driving the van in connection with the maintenance of Imperial’s property. The Court dismissed Imperial’s defense that Sunday was Laraga’s day off due to the lack of supporting evidence.

Building on this, the Court clarified that once the plaintiff establishes the employer-employee relationship and that the employee was acting within the scope of their assigned tasks, a presumption arises that the employer was negligent in the selection and supervision of the employee. It is then up to the employer to present evidence to rebut this presumption by showing they exercised the diligence of a good father of a family. In this instance, Imperial failed to provide sufficient evidence to prove that he exercised due diligence in the selection and supervision of Laraga. His self-serving testimonies about financing Laraga’s driving lessons were not supported by documentary proof.

Furthermore, the Court addressed Imperial’s claim that the official receipts for medical and hospital bills were not competent evidence of actual damages due to a lack of authentication. The Court noted that while official receipts are private documents and must be authenticated, this can be achieved by presenting a witness who saw the document executed or written, or by providing evidence of the genuineness of the signature or handwriting of the maker. Mary Lou Bayaban’s testimony regarding the circumstances of the accident and the expenses incurred, along with the presentation of the original receipts, constituted sufficient authentication.

Additionally, the Court reinstated the award of temperate damages for the loss of earning capacity. Temperate damages are awarded when some pecuniary loss has been suffered, but its amount cannot be proved with certainty. Even though the Bayaban Spouses could not provide definitive proof of income lost during their incapacitation, they were still entitled to compensation for their inability to work. The Court clarified that these damages were distinct from the actual damages awarded for medical expenses.

FAQs

What was the key issue in this case?	The key issue was determining the extent of an employer’s liability for the negligent actions of their employee, specifically whether the employee was acting within the scope of their assigned tasks at the time of the accident.
What are Articles 2176 and 2180 of the Civil Code?	Article 2176 defines quasi-delict as fault or negligence causing damage to another. Article 2180 extends this liability, holding employers responsible for the damages caused by their employees acting within the scope of their assigned tasks.
What does it mean for an employee to be acting within the scope of their assigned tasks?	An act is considered within the scope of employment if it is done by an employee in furtherance of the interests of the employer or for the account of the employer at the time of the injury or damage.
Who has the burden of proof in establishing the employer’s liability?	The plaintiff must first prove the existence of an employer-employee relationship and that the employee was acting within the scope of their assigned tasks. Once these are established, the burden shifts to the employer to prove they exercised due diligence in selecting and supervising the employee.
What constitutes due diligence in the selection and supervision of an employee?	Due diligence requires an employer to take reasonable steps to ensure that their employees are competent and capable of performing their assigned tasks without negligence. This may include providing training, conducting background checks, and implementing safety protocols.
What is the difference between actual and temperate damages?	Actual damages are compensation for losses that can be proven with certainty, such as medical expenses. Temperate damages are awarded when some pecuniary loss has been suffered, but its amount cannot be proved with certainty.
What is the significance of original receipts in proving damages?	Original receipts are considered the best evidence of actual damages incurred. While they are private documents that require authentication, the testimony of the person to whom the receipts were issued can serve as sufficient authentication.
Can an employer be held liable even if the employee’s negligence occurred outside of regular working hours?	Yes, if the employee was still acting within the scope of their assigned tasks at the time of the negligence. In this case, the fact that the accident occurred on a Sunday did not absolve the employer of liability because the employee was still furthering the employer’s interests.

This case serves as a crucial reminder to employers about the extent of their liability for the actions of their employees. By understanding the burden of proof and the importance of exercising due diligence in the selection and supervision of employees, employers can take steps to mitigate their risk and avoid potential liability.

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: RAUL S. IMPERIAL, VS. HEIRS OF NEIL BAYABAN, G.R. No. 197626, October 03, 2018