Mercury Drug Corporation v. Atty. Rodrigo B. Libunao

Summary

This case involves a petition for review challenging the Court of Appeals' decision holding Mercury Drug Corporation liable for damages caused by security guard Remigio Sido's tortious acts against lawyer Rodrigo Libunao. The incident occurred when Sido allegedly assaulted Libunao after demanding to see his receipt at the drugstore. The Supreme Court reversed the lower courts' decisions, ruling that Mercury Drug was not liable under Article 2180 of the Civil Code because Sido was not its employee but rather an employee of Black Shield Security Services Corporation. The Court relied on the respondent's own judicial admission, witness testimonies, and the security service contract clearly establishing the agency relationship. The decision reinforced the principle that security agencies, not their clients, are liable for their guards' wrongful acts, as the client has no role in selecting or directly employing the guards.