Perla Compania de Seguros v. Sps. Gaudencio Sarangaya Iii

Summary

This case involves a fire that originated from a company car and destroyed the Sarangaya spouses' commercial building and residence. Perla Compania de Seguros and its branch manager Bienvenido Pascual were sued for damages based on quasi-delict. The Supreme Court applied the doctrine of res ipsa loquitur to establish negligence, finding that car fires don't ordinarily occur without negligence, the vehicle was under Pascual's exclusive control, and the property owners didn't contribute to the incident. The Court rejected the caso fortuito defense, noting Pascual's failure to properly maintain the 14-year-old vehicle. The insurance company was held vicariously liable under Article 2180 of the Civil Code for failing to exercise due diligence in supervising its employee, particularly in establishing maintenance guidelines for company vehicles. The case was remanded for additional evidence on actual damages.