Caravan Travel v. Ermilinda R. Abejar

Summary

This Supreme Court case established important precedents on employer liability for vehicular accidents and standing to sue for quasi-delict damages. Caravan's employee Jimmy Bautista, driving a company van, hit and killed Jesmariane Reyes. Reyes' aunt Ermilinda Abejar, who raised her and exercised substitute parental authority, sued for damages. The Court held that registered vehicle owners bear primary liability for accidents, creating a disputable presumption of Article 2180 compliance that shifts burden to employer to prove due diligence or scope limitations. The Court recognized persons exercising substitute parental authority as 'ascendants' entitled to moral damages under Article 2206(3). Caravan failed to prove due diligence, having hired Bautista with only a non-professional license violating transportation law. The decision harmonizes the registered-owner rule with Civil Code employer liability provisions.