Maria Benita A. Dulay v. The Court of Appeals

Summary

This landmark case arose when a security guard shot and killed a lawyer during an altercation while on duty. The victim's widow sued the security companies for vicarious liability, but lower courts dismissed the case ruling that intentional acts don't constitute quasi-delict under Article 2176. The Supreme Court reversed, establishing the crucial doctrine that Article 2176 covers both negligent and intentional acts, not just negligence. The Court clarified that employers bear direct and immediate liability under Article 2180 for employee acts within scope of duties, with a presumption of negligence in selection or supervision. This decision significantly expanded the scope of tort liability and employer responsibility under Philippine civil law, allowing civil actions to proceed independently of criminal cases for intentional harmful acts.