Metro Manila Transit Corporation v. The Court of Appeals

Summary

This Supreme Court case established important precedents regarding employer vicarious liability in vehicular accidents. MMTC, a government-owned transit corporation, sought to avoid liability for its bus driver's negligence by claiming due diligence in employee selection and supervision. While the trial court accepted MMTC's generalized testimonial evidence about company procedures, the Court of Appeals and Supreme Court rejected this defense, finding that mere testimonies about the existence of hiring and supervisory procedures, without documentary proof of actual compliance and implementation, were insufficient to overcome the legal presumption of employer negligence. The Court emphasized that employers must present convincing evidence of actual, not just theoretical, due diligence in both selection and supervision of employees to avoid vicarious liability under Article 2180 of the Civil Code.