Jose S. Roque, Jr. v. Jaime T. Torres

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.