Mencorp Transport Systems v. Heirs of Liberato G. Libatique

Summary

This case involved the vicarious liability of Mencorp Transport Systems for a fatal vehicular accident caused by its bus driver's negligence. In 2000, the company's bus driver attempted to overtake a jeep on a highway with an oncoming truck, resulting in a collision that killed passenger Liberato Libatique. The Supreme Court affirmed that the driver was negligent in violating traffic rules by overtaking when the opposite lane was not clear. While Mencorp proved due diligence in driver selection, it failed to establish adequate supervision through mere testimonial evidence. The Court sustained the company's solidary liability but reduced the damages for loss of earning capacity from P2.19 million to P1 million as temperate damages, finding the original award speculative due to an expired employment contract. The decision reinforces employer liability under Article 2180 of the Civil Code and emphasizes the need for concrete evidence to prove due diligence in both employee selection and supervision.