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FILAMER CHRISTIAN INSTITUTE v. IAC

FACTS:

The case involves a dispute between the private respondents, heirs of the late Pontenciano Kapunan, and the petitioner Filamer Christian Institute. The private respondents seek reconsideration of the Supreme Court's decision, which ruled that the petitioner is not liable for the injuries caused by its co-defendant Funtecha. The Supreme Court initially held that Funtecha was not an authorized driver for whose acts the petitioner shall be directly and primarily answerable, and that Funtecha was merely a working scholar and not considered an employee of the petitioner. The private respondents argue that Funtecha is indeed an employee of the petitioner and that the petitioner should be held liable under Article 2180 of the Civil Code. Upon re-examination of the relevant laws and facts, the Supreme Court reconsiders its decision and reinstates the decision of the Court of Appeals. It is established that Funtecha was a working student and part-time janitor of the petitioner. He was allowed to take over a school vehicle from the regular driver, Allan Masa, on his way home. The vehicle swerved and hit Kapunan, causing his injuries. Allan, who also served as a security guard of the petitioner, testified that driving the vehicle to and from the house where he and Funtecha resided was an act in furtherance of the petitioner's interests. It is found that the school president, who is Allan's father, had knowledge of the routine practice of driving the vehicle home and Funtecha's possession of a student driver's license. The Supreme Court concludes that Funtecha's act of taking over the wheel was done on behalf of his employer, for the purpose of the service intended by the petitioner-school.

ISSUES:

  1. Whether there exists an employer-employee relationship between the petitioner and its co-defendant Funtecha.

  2. Whether the petitioner is liable for the injuries caused by Funtecha.

RULING:

  1. The Court ruled that Funtecha is considered an employee of the petitioner Filamer Christian Institute. Although Funtecha was a working student and assigned to clean the school premises for only two hours each school day, he was still an employee of the school.

  2. The Court held that the act of Funtecha in taking over the steering wheel and driving the school jeep was done for and on behalf of his employer. Therefore, the petitioner Filamer Christian Institute cannot deny any responsibility for Funtecha's actions.

PRINCIPLES:

  • In cases of employer liability, Article 2180 of the Civil Code states that an injured party may seek recourse against both the servant and the petitioner for whom the servant was performing an act in furtherance of the interest and for the benefit of the petitioner.

  • An employer-employee relationship may exist even if the employee is a working student and assigned only to perform specific tasks for a limited period.

  • The scope of liability of an employer includes any act done by an employee in furtherance of the interests of the employer, regardless of whether it falls within the employee's assigned tasks.