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SUPREME TRANSLINER INC. v. CA

FACTS:

The petitioners, Supreme Transliner Inc. and Felipe Sia, are the registered owners of a bus driven by co-petitioner Novencio Flores. On September 24, 1990, the bus collided with a passenger jeepney owned and registered in the name of Marcelino Villones and driven by Reynaldo Decena. As a result of the collision, private respondents Gloria and Lotis Brazal, who were passengers in the jeepney, suffered injuries. They filed a case for damages against petitioners based on quasi-delict and against Villones and Decena for breach of contract. Petitioners filed a third-party complaint against Country Bankers Insurance Company, the insurer of the Supreme Transliner bus. During the trial, testimonies were presented by both parties, with Gloria Brazal testifying about the incident and Decena and Villones offering their own testimonies along with their witnesses. Petitioners presented Flores and the Manager of Supreme Transliner as witnesses. The trial court rendered its judgment, holding petitioners primarily liable for the damages and ordering them to pay the private respondents. The court also ordered Country Bankers to pay the third-party plaintiffs a certain amount. Petitioners appealed to the Court of Appeals, challenging the decision of the trial court. Country Bankers filed a manifestation and motion, stating that it had already settled its maximum liability under the policy and requesting exclusion from the case. The Court of Appeals affirmed the judgment of the trial court, subject to certain modifications.

ISSUES:

  1. Whether petitioners Supreme Transliner Inc. and Felipe Sia are liable to private respondents for damages.

  2. Whether Sia is solidarily liable with driver Flores.

  3. Whether the amount of damages awarded by the trial court is proper.

RULING:

  1. Yes, petitioners Supreme Transliner Inc. and Felipe Sia are liable to private respondents for damages. The Court of Appeals affirmed the trial court's finding that Flores was negligent in operating the bus and that Sia failed to exercise the diligence of a good father of a family in the choice, supervision, and direction of his employees.

  2. Yes, Sia is solidarily liable with driver Flores. The Court of Appeals affirmed the trial court's ruling that Sia, as the registered owner of the bus, is primarily liable for the damages suffered by the private respondents.

  3. The Court of Appeals affirmed the trial court's award of damages, which consisted of actual damages, moral damages, and attorney's fees, in the amounts specified by the trial court.

PRINCIPLES:

  • Owners of vehicles are primarily liable for damages caused by the negligence of their drivers, under the principle of vicarious liability.

  • Registered owners of vehicles have a duty to exercise the diligence of a good father of a family in the choice, supervision, and direction of their employees.

  • Insurance companies have an obligation to act upon insurance claims submitted to them and may be held liable for damages if they fail to fulfill their obligations under the insurance policy.