Triple-V Food Services v. Filipino Merchants Insurance Company

Summary

This case involves the liability of a restaurant for a car stolen from its valet parking service. When Mary JoAnne De Asis used Triple-V's valet parking while dining, her employer's car was stolen. The insurance company FMICI, after indemnifying the employer, sued Triple-V as subrogee. Triple-V argued that a liability waiver on the parking ticket exempted them from responsibility. The Supreme Court affirmed lower courts' rulings that a deposit relationship was created, making Triple-V liable as depositary. The liability waiver clause was deemed invalid as a one-sided contract of adhesion. The Court found valid insurance subrogation since theft coverage existed under the policy. This case establishes that valet parking services create depositary relationships with corresponding duties of care, and exclusionary clauses in parking tickets cannot absolve service providers from negligence liability.