Cecilia Yambao v. Melchorita C. Zuñiga

Summary

The Supreme Court affirmed lower courts' finding that bus owner Cecilia Yambao was liable for the death of pedestrian Herminigildo Zuñiga caused by her employee-driver's negligent operation of her passenger bus. The Court applied Article 2180 of the Civil Code on employer liability for employee torts, rejecting the common carrier liability theory used by the trial court since no contractual relationship existed. Yambao failed to rebut the legal presumption of negligence in employee selection and supervision, admitting the driver submitted required documents only on the accident date itself and providing no evidence of safety training or oversight programs. The decision demonstrates the strict standard for employers to avoid vicarious liability for employee negligence through proof of due diligence in both selection and supervision.