- Petitioner
- Jose S. Roque, Jr.
- Respondent
- Jaime T. Torres
- Citation
- G.R. No. 157632
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Chico-Nazario, J.
- Decided
- December 6, 2006
Summary
This case involves civil liability for damages arising from a property dispute. Jose Roque, Jr., administrator of land titled to his son, was shot and mauled by security guards hired by Jaime Torres, who falsely claimed ownership of the property. The incident resulted in Roque's paralysis, blindness, and eventual death. The RTC awarded damages totaling P1.65 million, but the Court of Appeals reversed, applying the rule that security agencies, not clients, are liable for guards' acts. The Supreme Court reinstated the RTC decision, holding Torres liable under Article 2176 for quasi-delict despite not being the guards' employer. The Court found Torres acted in bad faith by hiring guards to secure property he knew belonged to another, violating the good faith principle under Article 19. The decision establishes that clients of security agencies can still face civil liability for damages when their instructions or bad faith acts contribute to harm, even if they are not the guards' direct employers.
Intellegal Wiki · Key Holding
Reversed the CA and reinstated the RTC judgment, holding that although the client was not the security guards' employer under Article 2180, he was liable under Article 2176 for quasi-delict, having acted in bad faith in violation of Article 19 by posting guards on property he knew was titled to another.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.