Raul S. Imperial v. Heirs of Neil Bayaban

Summary

The Supreme Court affirmed the vicarious liability of employer Raul Imperial for damages caused by his employee-driver William Laraga's negligent operation of Imperial's van, which collided with a tricycle carrying the Bayaban spouses. The Court held that respondents successfully proved Laraga was acting within the scope of his assigned tasks when the accident occurred, creating a disputable presumption of employer negligence in selection and supervision. Imperial failed to rebut this presumption with evidence of due diligence. The Court reinstated temperate damages deleted by the Court of Appeals, clarifying that temperate and actual damages can be awarded simultaneously when covering distinct pecuniary losses. The decision reinforces the principle that employers bear solidary liability for employee torts committed within the scope of employment, emphasizing the burden of proof requirements and the presumption of negligence under Article 2180 of the Civil Code.