Philippine Supreme Court Jurisprudence > Year 2019 > September 2019 Decisions > G.R. No. 224186 - SPOUSES EMILIO MANGARON, JR. AND ERLINDA MANGARON, PETITIONERS, v. HANNA VIA DESIGN & CONSTRUCTION, OWNED AND MANAGED BY ENGR. JAMES STEPHEN B. CARPE, RESPONDENT:

Before the Court is a Petition for Review on Certiorari¹ assailing the Decision² dated October 20, 2015 and the Resolution³ dated April 14, 2016 of the Court of Appeals (CA) in CA-G.R. SP No. 13 8259.

The Relevant Antecedents
The case stemmed from a complaint for damages under Article 2184 of the Civil Code, in relation to Article 2180 of the same Code filed by spouses Emilio Mangaron, Jr. and Erlinda Mangaron (petitioners) against Hanna Via Design and Construction - Deepwell Drilling Division (respondent), Power Supply and Equipment Parts (Power Supply) and their company driver, Crestino T. Bosquit (Bosquit).⁴

In said complaint, petitioners invoked respondent's vicarious liability for the negligent driving of Bosquit of an Isuzu Truck with Plate Number PLM 612 (subject vehicle), which bumped and dragged their vehicle, a Ford Ranger Pick-Up with Plate Number XJZ-830. Said collision caused serious physical injuries to petitioners, who were confined for a whole month at the Davao Doctors Hospital in Davao City.⁵

After the petitioners presented their evidence and rested their case, respondent filed a Motion for Demurrer to Evidence.⁶ Among others, respondent questioned the jurisdiction of the RTC over the case, contending that the complaint is actually a criminal action for reckless imprudence resulting to physical injuries. Thus, the complaint should have been filed in Davao City where the vehicular incident happened.

In an Order⁷ dated May 20, 2014, the Regional Trial Court of Malolos City, Bulacan, Branch 11 (RTC), denied the motion. The RTC held that the issues raised, that is, the ownership of the subject vehicle, respondent's working relationship with Bosquit, and its culpability, are matters of evidence. Moreover, the RTC maintained its jurisdiction over the case as the case is clearly civil in nature, a complaint for damages.

Respondent filed a Motion for Reconsideration, which was denied in an Order⁸ dated September 26, 2014.

Impugning the jurisdiction of the RTC, respondent filed a Petition for Certiorari before the CA.

In a Decision⁹ dated October 20, 2015, the CA upheld the jurisdiction of the RTC as the complaint spelled out a civil complaint for damages. However, the CA reversed the ruling of the RTC insofar as the denial of respondent's demurrer to evidence. Ruling that the RTC committed grave abuse of discretion, the CA opined that the case should have been dismissed because the registered owner of the Isuzu Truck is Power Supply, and not respondent. Thus:

WHEREFORE, premises considered, the petition is GRANTED. The Orders dated May 20, 2014 and September 26, 2014 of the Regional Trial Court, Branch 11 (XI), Malolos City, Bulacan in Civil Case No. 103-M-2011 are hereby REVERSED AND SET ASIDE.

SO ORDERED.

Unsatisfied, petitioners filed a Motion for Reconsideration, which was denied in a Resolution¹⁰ dated April 14, 2016.

Hence, this Petition.

In essence, petitioners assail the ruling of the CA in: (a) giving due course to the Petition for Certiorari filed by respondent, as the assailed May 20, 2014 Order is an interlocutory order denying a motion for demurrer to evidence; and (b) setting aside such Order when there exists sufficient basis for the same.

The Issue
Summarily, the issue in this case is the propriety of the denial of the motion for demurrer to evidence.


Petitioners argue that the CA erred in giving due course to the Petition for Certiorari, being the improper remedy.

The Court disagrees.

An order denying a demurrer to evidence is an interlocutory order for it does not completely dispose of a case. As an interlocutory order, the remedy of an appeal is expressly excluded by Rule 41¹¹ of the Rules of Court. Alternatively, as an exception to the general rule that a writ of certiorari is not available to challenge interlocutory orders of the trial court, a party may file a certiorari petition under Rule 65 of the Rules of Court, alleging that the denial is tainted with grave abuse of discretion amounting to lack or in excess of jurisdiction.¹²

As the remedy of certiorari lies, the determination as to whether the instant case falls under the exception, i.e., whether the trial court's denial of the demurrer to evidence is issued with grave abuse of discretion, is now subject of this Court's judicial power of review.

A demurrer to evidence is defined as an objection or exception by one of the parties in an action at law, to the effect that the evidence which his adversary produced is insufficient in point of law (whether true or not) to make out his case or sustain the issue.¹³

After a careful review of the case, the Court agrees with the CA in finding that the denial of the motion for demurrer to evidence was tainted with grave abuse of discretion. In reversing and setting aside the May 20, 2014 and September 26, 2014 Orders, the CA essentially found that the RTC failed to consider the application of the registered owner rule.

In accordance with the law on compulsory motor vehicle registration, this Court has consistently ruled that, with respect to the public and third persons, the registered owner of a motor vehicle is directly and primarily responsible for the consequences of its operation regardless of who the actual vehicle owner might be.¹⁴

In this case, it is undisputed that the registered owner of the subject vehicle is Power Supply. However, petitioners try to convince this Court to pronounce a ruling moored on a pragmatic stance, that is, by ruling on respondent's liability based on its admission of its ownership over the subject vehicle.

On this note, the Court stresses that the registered owner rule is clear and straightforward. Its rationale is to fix liability on the owner of a motor vehicle involved in an accident by clear identification through registration, to wit:

Registration is required not to make said registration the operative act by which ownership in vehicles is transferred, as in land registration cases, because the administrative proceeding of registration does not bear any essential relation to the contract of sale between the parties, but to permit the use and operation of the vehicle upon any public highway (section 5 [a], Act No. 3992, as amended.) 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 therefore 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.¹⁵ (Citation omitted)

Truly, what the law seeks to prevent is the avoidance of liability in case of accidents to the detriment of the public. In case an accident occurs, the liability becomes definite and fixed as against a specific person, so that the victim may be properly indemnified without having to go through the rigorous and tedious task of trying to identify the owner or driver of the concerned vehicle.

Thus, the registration of the vehicle's ownership is indispensable in determining imputation of liability; thus, whoever has his/her name on the Certificate of Registration of the offending vehicle becomes liable in case of any damage or injury in connection with the operation of such vehicle inasmuch as the public is concerned. The case of Equitable Leasing Corporation v. Suyom¹⁶ is illustrative:

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. 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, x x x

As between the registered owner and the driver, the former is considered as the employer of the latter, and is made primarily liable for the tort under Article 2176 in relation with Article 2180 of the Civil Code.¹⁷

However, the application of the registered owner rule does not serve as a shield of the offending vehicle's real owner from any liability. The law is not inequitable. Under the principle of unjust enrichment, the registered owner who shouldered such liability has a right to be indemnified by means of a cross-claim as against the actual employer of the negligent driver.¹⁸ In this way, the preservation of the rights of the parties concerned would be upheld while championing the public policy behind the registered owner rule.

WHEREFORE, premises considered, the Petition is hereby DENIED. Accordingly, the Decision dated October 20, 2015 and the Resolution dated April 14, 2016 of the Court of Appeals in CA-G.R. SP No. 138259 are AFFIRMED in toto.

SO ORDERED.

Carpio, (Chairperson),^* Caguioa, Reyes, J. Jr., Lazaro-Javier, and Zalameda, JJ., concur.

Endnotes:

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^* Acting Chief Justice per Special Order No. 2703 dated September 10, 2019.

¹Rollo, pp. 25-35.

² Penned by Associate Justice Remedios A. Salazar-Fernando, with Associate Justices Priscilla J. Baltazar-Padilla and Socorro B. Inting, concurring; id at 9-18.

³ Id. at 20-21.

⁴ Id at 10.

⁵ Id.

⁶ Id.

⁷ Penned by Judge Basilio R. Gabo, Jr.; id at 55.

⁸ Id. at 56.

⁹ Supra note 2.

¹⁰ Supra note 3.

¹¹ Section 1. Subject of appeal. � An appeal may be taken from a judgment or final order that completely disposes of the case, or of a particular matter therein when declared by these Rules to be appealable.

No appeal may be taken from:
x x x x
(c) An interlocutory order;
x x x x

In all the above instances where the judgment or final order is not appealable, the aggrieved party may file an appropriate special civil action under Rule 65.

¹²See Choa v. Choa, 441 Phil. 175, 182 (2002).

¹³ Id. at 183.

¹⁴FEB Leasing and Finance Corporation v. Spouses Baylon, 668 Phil. 184, 195 (2011).

¹⁵Metro Manila Transit Corporation v. Cuevas, 759 Phil. 286, 292-293 (2015).

¹⁶ 437 Phil. 244, 255 (2002).

¹⁷See Filcar Transport Services v. Espinas, 688 Phil. 430, 436 (2012).

¹⁸ Id. at 442.