This case is about whether a vehicle owner is liable for damages caused by the driver of that vehicle. According to the facts, a collision occurred between two jeepneys, resulting in deaths and injuries. The driver of one jeepney had only been licensed for 3 months. The owners of that jeepney, the Hernandez spouses, leased the vehicle to the driver daily but claimed they were not liable since they were not in the vehicle. The court found the Hernandez spouses solidarily liable with the driver under Civil Code provisions for employer liability and quasi-delict. The spouses argued they had a lease agreement, but the court found an employer-employee relationship existed to protect the public from reckless drivers who could not
This case is about whether a vehicle owner is liable for damages caused by the driver of that vehicle. According to the facts, a collision occurred between two jeepneys, resulting in deaths and injuries. The driver of one jeepney had only been licensed for 3 months. The owners of that jeepney, the Hernandez spouses, leased the vehicle to the driver daily but claimed they were not liable since they were not in the vehicle. The court found the Hernandez spouses solidarily liable with the driver under Civil Code provisions for employer liability and quasi-delict. The spouses argued they had a lease agreement, but the court found an employer-employee relationship existed to protect the public from reckless drivers who could not
This case is about whether a vehicle owner is liable for damages caused by the driver of that vehicle. According to the facts, a collision occurred between two jeepneys, resulting in deaths and injuries. The driver of one jeepney had only been licensed for 3 months. The owners of that jeepney, the Hernandez spouses, leased the vehicle to the driver daily but claimed they were not liable since they were not in the vehicle. The court found the Hernandez spouses solidarily liable with the driver under Civil Code provisions for employer liability and quasi-delict. The spouses argued they had a lease agreement, but the court found an employer-employee relationship existed to protect the public from reckless drivers who could not
This case is about whether a vehicle owner is liable for damages caused by the driver of that vehicle. According to the facts, a collision occurred between two jeepneys, resulting in deaths and injuries. The driver of one jeepney had only been licensed for 3 months. The owners of that jeepney, the Hernandez spouses, leased the vehicle to the driver daily but claimed they were not liable since they were not in the vehicle. The court found the Hernandez spouses solidarily liable with the driver under Civil Code provisions for employer liability and quasi-delict. The spouses argued they had a lease agreement, but the court found an employer-employee relationship existed to protect the public from reckless drivers who could not
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HERNANDEZ v.
DOLOR
*This is a case about how an employer is solidarily liable for the acts of his employee
Facts: Boyet Dolor and Oscar Valmocina died as a result of a collision between an owner type jeep driven by Dolor and a passenger type jeep driven by herein petitioner Juan Gonzales. Other passengers also suffered physical injuries. Consequently, respondents commenced an action for damages against petitioners, driver (Gonzales) and the owner of the vehicle (spouses Hernandez).
During the trial, the following were established:
1. The owner type jeep was travelling at a moderate speed 2. The passenger jeepney was travelling fast when it bumped into the owner 3. Petitioner Juan Gonzales obtained his professional driver’s license only 3 monthes before the accident occurred. 4. Hernandez spouses leases the jeep to the driver on a daily basis.
Hernandez spouses are contending that they should not be impleaded in the case since they were not in the jeep during the accident. They also claimed that there is no employer-employee relationship that exists between them and the driver since they only lease the jeep to the latter.
Trial Court held rendered the decision in favor of the victims and held Hernandez spouses solidarily liable. CA affirmed the decision but with a few modifications on the amount of the damages.
Issue: W/N Hernandez spouses are solidarily liable with Juan Gonzales
Held: Hernandez spouses are solidarily liable.
1. Even though they were not in the jeep during the accident, they are still answerable under several provisions of the Civil Code namely:
Article 2180… employers shall be liable for the damages caused by their employees and household helpers acting within the scope of their assigned tasks, even thought eh former are not engaged in any business or activity
Article 2176. Whoever by act or omission causes damage to another, there
being fault or negligence, is obliged to pay for the damage done. Such fault or negligence, if there is no pre-existing contractual relation between the parties, is called a quasi-delict and is governed by the provisions of this Chapter
While the above provisions do not expressly provide for the solidary liability, they should be read in consonance with Article 2180 – one can be liable for the acts or omission of another whom he is responsible for, meaning that an employer is accountable for the actions of his employees. Article 2194 categorically states that responsibility of two or more persons who are liable for quasi-delict is solidary. 2. The Hernandez spouses maintained that Julian Gonzales is not their employee because the latter pays them daily for the use of the jeepney. They argued that they are practicing a lease agreement using the “boundary system”. SC held that there exists an employer-employee relationship because by agreeing to the Hernandez, there would be a villation of the Public Service Law and we are going to place the riding public at the mercy of reckless and irresponsible drivers because most drivers are in no position to pay for damages when accidents occur.
