Nostradamus Villanueva vs. Priscilla R. Domingo, Et Al.

Nostradamus Villanueva vs. Priscilla R. Domingo, et al. [G.R. No. 144274, 20 September 2004, 438 SCRA 485]

Facts:

A car driven by Renato Ocfemia hit a car driven by Leandro Domingo. The registered owner of Ocfemia’s vehicle was Nostradamus Villanueva, although Villanueva has traded/swapped the vehicle for a Pajero owned by Albert Jaucian/Auto Palace Car Exchange.

The Assistant City Prosecutor of Manila recommended the filing of an Information for reckless imprudence resulting to damage to property and physical injuries. The trial court found Villanueva liable and ordered him to pay damages. The Court of Appeals affirmed the trial court but deleted the award for attorney’s and appearance fees. Villanueva files a petition for review with the Supreme Court. Issue:

Whether a registered owner of a vehicle may be held liable for damages arising from an accident involving the said vehicle while it was being operated by the employee of the vehicle’s buyer without the latter’s consent and knowledge

Held/Ratio: Yes, a registered owner of any vehicle is directly and primarily liable to the public and third persons while it is being operated. The petition for review is denied and the Court of Appeals decision is affirmed. The public has a right to assume that the registered owner is the actual owner, to make it easier for them to enforce actions for injuries caused to them by vehicles negligently operated. However, the registered owner may recover from the person to whom he had sold, assigned, or conveyed the vehicle via a third-party complaint. The registered owner of any vehicle, even if not used for a public service, should be primarily responsible to the public or third persons while the vehicle is being driven on the streets. The main aim of registration is to identify the owner so that if any accident happens, responsibility can be fixed on a definite individual–the registered owner. The primary purpose is to make certain that the violator shall not escape because of lack of means to discover him. The law, with its aim in mind, does not relieve him directly of the responsibility that the law places upon him as an incident or consequence of registration. If a registered owner is allowed to prove who the supposed transferee is, it would be easy for him to escape responsibility and transfer it to an indefinite person or to one who

possesses no property with which to respond financially for the injury or damage. Whether the driver is authorized by the actual owner is irrelevant in determining the liability of the registered owner. To require so would defeat the purpose of the enactment of motor vehicle registration. The registered owner is the operator with respect to the public and third persons. The owner of record is the employer of the driver, the actual owner being considered merely as his agent.