Pedro T. Layugan v. Intermediate Appellate Court

Summary

Pedro Layugan was injured when helping repair a truck tire along a highway, after being struck by Godofredo Isidro's vehicle driven by Daniel Serrano. The trial court awarded damages to Layugan, but the Intermediate Appellate Court reversed, applying res ipsa loquitur to find the parked truck's positioning negligent. The Supreme Court granted Layugan's petition, finding the appellate court erred in its application of res ipsa loquitur. The Court established that adequate warning devices were present and that Serrano was negligent for not properly inspecting his vehicle before driving, discovering his brake failure was due to a cut fluid pipe. The Court held Isidro liable under Article 2180 of the Civil Code for failing to exercise proper supervision over his employee, reinstating the trial court's damage award. The case clarifies the proper application of res ipsa loquitur in vehicular accident cases and employer liability for employee negligence.