R Transport Corporation v. Luisito G. Yu

Summary

This case involves employer liability for a fatal bus accident where Loreta Yu was killed by a bus operated by R Transport Corporation but registered under Metro Manila Transport Corporation. The Supreme Court affirmed lower courts' findings that the bus driver was negligent, evidenced by the victim's severe injuries indicating excessive speed in a busy commercial area. The Court applied Article 2180 of the Civil Code establishing presumptive employer liability for employee negligence, which R Transport failed to rebut by proving due diligence in driver selection and supervision. The Court rejected R Transport's argument that non-ownership of the registered vehicle absolves liability, emphasizing that actual operators bear responsibility. The decision reinforces the principle of protecting the public by holding both registered owners and actual operators jointly liable, distinguishing this tort case from contract of carriage where liability rules differ.