Omc Carriers v. Spouses Roberto C. Nabua

Summary

This case involves a vehicular accident where a company-owned tanker struck and killed an 18-year-old driver. The Supreme Court affirmed the lower courts' finding that the company driver's negligence was the proximate cause of the accident, rejecting the company's defense of due diligence in employee selection and supervision. The Court emphasized that employers bear the burden of proving due diligence through documentary evidence, not mere oral testimony. The case established important precedents on employer liability under Article 2180 of the Civil Code, the evidentiary requirements for proving due diligence in employee supervision, and the proper computation of damages in wrongful death cases. The Court reduced several damage awards to conform with prevailing jurisprudence, particularly limiting actual damages to amounts supported by receipts and standardizing death indemnity and moral damages. The decision reinforced that presumption of employer negligence can only be overcome by clear documentary evidence of proper employee selection and supervision.