Apolonio S. Tanjangco v. Annalie E. Rodrin

Summary

This case involves the liability of a registered vehicle owner for damages caused by a vehicular accident. Tanjangco sold a Mazda van to Buenaventura through a conditional deed of sale, with full payment completed in 1992. However, before the vehicle registration was transferred to Buenaventura's name, the van, driven by Reales (an Arizona Transport employee), injured Rodrin in an accident. The Supreme Court affirmed that despite the actual sale, Tanjangco as the registered owner remained jointly and solidarily liable with the driver and employer for damages to third parties under Article 2180 of the Civil Code. The Court emphasized that vehicle registration with the Land Transportation Office is essential to bind third parties, and unregistered transfers do not relieve the registered owner of liability. Buenaventura was ordered to reimburse Tanjangco for amounts paid to the victim. The case establishes the principle that registered ownership creates liability regardless of actual ownership or possession when vehicle registration transfers are not properly completed.