Mariano C. Mendoza v. Spouses Leonora J. Gomez

Summary

This case involves a vehicular accident where petitioner Mendoza, driving a bus registered to petitioner Lim, collided with respondents' truck, causing injuries and property damage. The Supreme Court affirmed the lower courts' finding of quasi-delict liability under Article 2176 of the Civil Code against Mendoza and vicarious liability under Article 2180 against Lim as the registered owner. However, the Court partially granted petitioners' appeal by deleting the awards of moral damages and attorney's fees. The Court found no evidence that respondents suffered mental anguish or besmirched reputation required for moral damages, and that the trial court failed to justify the attorney's fees award. The Court maintained awards for actual damages (vehicle repairs and medical expenses), exemplary damages due to gross negligence, and costs of suit. The decision reinforces the principle that registered owners of motor vehicles are vicariously liable for accidents caused by their drivers, and establishes strict requirements for awarding moral damages and attorney's fees in quasi-delict cases.