Metro Manila Transit Corporation (Mmtc) v. Court of Appeals

Summary

This consolidated case involves the death of 16-year-old Liza Rosalie who was struck by an MMTC bus driven by Pedro Musa on August 9, 1986. The Supreme Court established important precedents on employer vicarious liability under Article 2180 of the Civil Code, ruling that MMTC and Musa were jointly and severally liable for damages. The Court emphasized that employers must present concrete documentary evidence, not merely testimonial evidence, to prove they exercised diligence of a good father of a family in employee selection and supervision. The decision awarded comprehensive damages totaling over P1.9 million, including compensation for loss of earning capacity for a minor victim based on projected lifetime earnings. The case demonstrates the primary and solidary nature of employer liability in transportation tort cases and sets standards for proving due diligence defenses.