- Petitioner
- Spouses Francisco M. Hernandez
- Respondent
- Spouses Lorenzo Dolor
- Citation
- G.R. No. 160286
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Ynares-Santiago, J.
- Decided
- July 30, 2004
Summary
This case arose from a vehicular collision between two jeepneys on December 19, 1986, resulting in two deaths and multiple injuries. The Supreme Court upheld the solidary liability of jeepney owners and their drivers under the Civil Code's quasi-delict provisions, rejecting the boundary system defense. The Court emphasized that allowing vehicle owners to escape liability through lease arrangements would endanger public safety and violate the Public Service Law. The decision clarified that Articles 2180 and 2194 of the Civil Code establish solidary liability for employers and employees in tort cases. The Court approved temperate damages for unquantifiable losses while deleting attorney's fees for insufficient legal basis, ultimately awarding over P400,000 in total damages to victims and their families.
Intellegal Wiki · Key Holding
Denied the petition, holding that the boundary system does not negate the employer-employee relationship on public-policy grounds and that jeepney owners are solidarily liable with their drivers under Articles 2180 and 2194; temperate damages were proper, but attorney's fees were deleted for lack of sufficient basis under Article 2208.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.