CASE DIGEST
Villanueva v. Domingo
G.R. No. 144274,
September 20, 2004
THIRD DIVISION, CORONA J.
Registered owner rule; Liability of Registered Owner of Motor Vehicles
We have consistently ruled that the
registered owner of any vehicle is directly and primarily responsible to the
public and third persons while it is being operated.
Priscilla R. Domingo was the registered owner of a silver Mitsubishi Lancer (Plate No. NDW 781), which was involved in a vehicular collision along South Superhighway while being driven by her son Leandro Luis R. Domingo. The other vehicle involved was a green Mitsubishi Lancer (Plate No. PHK 201), driven by Renato Ocfemia, who was drunk and unlicensed at the time. This vehicle was registered in the name of petitioner Nostradamus Villanueva, who claimed he had already swapped it with another vehicle and that the actual owner at the time was Albert Jaucian of Auto Palace Car Exchange. Villanueva contended that he was no longer liable since he no longer had possession or control of the vehicle, and Ocfemia was not his employee. The trial court and the Court of Appeals both found Villanueva liable, prompting the petition before the Supreme Court.
Whether the registered owner of a motor vehicle can be held liable for damages
resulting from an accident even if the vehicle was already transferred to
another person and operated without the registered owner's knowledge or
consent.
Yes. The Supreme Court affirmed the ruling of the Court of Appeals and
held that the registered owner is directly and primarily liable for damages
caused by the operation of the vehicle, regardless of actual ownership or
driver authorization. The Supreme Court have consistently ruled that the
registered owner of any vehicle is directly and primarily responsible to the
public and third persons while it is being operated.
To allow a
registered owner to escape liability by claiming that the driver was not
authorized by the new (actual) owner results in the public detriment the law
seeks to avoid. The main purpose of vehicle registration is the easy
identification of the owner who can be held responsible for any accident,
damage or injury caused by the vehicle... The protection that the law aims to
extend... would become illusory were the registered owner given the opportunity
to escape liability by disproving his ownership.
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