Hermana R. Cerezo v. David Tuazon

Summary

This case involves a bus-tricycle collision where tricycle driver David Tuazon sued bus owner Hermana Cerezo for damages under quasi-delict principles. After the Cerezo spouses were declared in default for failing to file an answer, the trial court awarded damages totaling over P172,000. Mrs. Cerezo then pursued multiple unsuccessful remedies including petition for relief from judgment, certiorari, and annulment of judgment, spanning nearly a decade. The Supreme Court affirmed her liability under Article 2180 of the Civil Code, emphasizing that employer liability for employee negligence is primary and direct, not subsidiary. The Court also ruled that the bus driver was not an indispensable party due to the solidary nature of quasi-delict obligations, and that jurisdictional defects were waived through the defendants' voluntary participation in proceedings.