Heirs of Catalina P. Mendoza v. Es Trucking

Summary

The Supreme Court reversed lower court decisions that dismissed a damages claim arising from a fatal vehicular accident. Catalina P. Mendoza was killed when struck by an ES Trucking prime mover truck in Zamboanga City. The Court found the driver negligent and established ES Trucking's vicarious liability under Article 2180 of the Civil Code. Significantly, the Court determined ES Trucking was a common carrier operating truck-for-hire services without proper LTFRB registration, contrary to its claims of being a private company. The Court found ES Trucking failed to exercise due diligence in employee selection and supervision, noting inadequate hiring procedures and failure to require proper certifications. The decision awarded comprehensive damages totaling P612,565.60 plus interest, emphasizing that entities cannot escape common carrier liability merely by failing to obtain required permits. The case establishes important precedents on vicarious liability, common carrier classification, and employer due diligence requirements in the transportation industry.