Filcar Transport Services vs. Jose A.

Espinas
G.R. No. 174156 June 20, 2012

BRION, J.

Facts:
On November 22, 1998, respondent Jose A. Spinas was driving his car, upon reaching an
intersection, at the instance of a green-lit traffic signal; he was hit by another vehicle while
traversing the intersection, hurling his vehicle clockwise. He was able to identify the plate
number UCF-545, and upon checking with the Land Transportation Office, the vehicle was
owned by Filcar Transport Services. Espinas filed an action before the Metropolitan Trial Court
of Manila against Filcar and its President, Mrs. Carmen Flor.

Flor denied liability alleging that the car was driven by the personal driver of her husband,
Timoteo Floresca; alleging further that Floresca was not an employee of Filcar, hence she should
not be held liable as an employer. The MeTC held that Filcar and Carmen Flor shall be held
liable for the damages incurred by Espinas. The Regional Trial Court affirmed the judgement of
the lower court; the Court of Appeals affirmed the decision with modifications, declaring only
Filcar to be exclusively liable for the damages since it has a separate and distinct personality
from that of its corporate owners; hence, this petition for review through certiorari.

Issue:
Whether or not Filcar is liable for the damages incurred by Espinas

Ruling:
Yes, because Filcar is vicariously liable for the damages caused by the vehicle registered
under its name. Under the vehicle registration law, the owner of the vehicle will be the one to
incur any liability, treating the identity of the driver at the time of the incident to be trivial and
consequential to the proceeding.

Under Article 2176 of the Civil Code, it is contemplated that a person is only liable for
the torts he himself has cause, however, Article 2180 imposes the vicarious liability to employers
of the person who incurred the accident. In this case, it is incorrect for Carmen to allege the
Floresca was not an employee of the company, hence Filcar should not have incurred any
liability; alleging the absence of any employer-employee relationship. It was held in Erezo et al.
vs. Jepte, that the owner of the vehicle shall be held liable for the damage caused by whoever is
the driver of the vehicle at the time; this is to ensure that there will be a definite identity to whom
the accountability shall be imposed upon; as such, any existence of an employer-employee is
irrelevant in this case. Upon these considerations, the Supreme Court denies this instant petition,
affirming the decision of the Supreme Court, with costs against Filcar Transportation Services.