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SPS. BENJAMIN C. MAMARIL v. BOY SCOUT OF PHILIPPINES

FACTS:

The case involves a dispute between Spouses Benjamin C. Mamaril and Sonia P. Mamaril (Sps. Mamaril) and the Boy Scout of the Philippines (BSP), AIB Security Agency, Inc. (AIB), Cesario Peña, and Vicente Gaddi. Sps. Mamaril are jeepney operators who paid BSP to park their vehicles inside the BSP compound. On May 26, 1995, one of their vehicles went missing and was not recovered. Sps. Mamaril alleged that the security guards of AIB, hired by BSP, were grossly negligent for allowing an unauthorized person to drive the vehicle out. The Regional Trial Court (RTC) held BSP, AIB, Peña, and Gaddi jointly and severally liable for the loss. The Court of Appeals (CA), while affirming the finding of negligence, absolved BSP from any liability, stating that the Guard Service Contract did not impose any obligation or liability on BSP. The CA also deleted the awards of damages and attorney's fees granted by the RTC. Sps. Mamaril filed a petition for review on certiorari, arguing that BSP should be held liable based on the Guard Service Contract and the parking ticket. They also questioned the deletion of the RTC's awards.

ISSUES:

  1. Whether BSP is liable for the loss of Sps. Mamaril's vehicle.

  2. Whether an employer-employee relationship exists between BSP and the security guards Peña and Gaddi.

  3. Whether or not the contract between BSP and AIB Security Agency includes any obligation or liability in favor of third persons.

  4. Whether or not the contractual relationship between the parties is one of lease.

  5. Whether or not BSP is liable for the loss suffered by Sps. Mamaril.

  6. Whether or not the exculpatory clause contained in the BSP issued parking ticket is void.

  7. Whether or not Sps. Mamaril are entitled to damages.

  8. Whether or not the petition should be granted.

RULING:

  1. No, BSP is not liable for the loss of Sps. Mamaril's vehicle. The negligent act of the security guards in allowing an unidentified person to drive out the vehicle was the proximate cause of the loss. BSP was not found to be negligent and there is no reversible error in absolving it of any liability for the loss.

  2. No, an employer-employee relationship does not exist between BSP and the security guards Peña and Gaddi. They were assigned to BSP by AIB pursuant to the Guard Service Contract. The negligence of Peña and Gaddi is imputed to AIB, their true employer. BSP cannot be held liable under Article 2180 of the Civil Code.

  3. The contract between BSP and AIB Security Agency does not include any obligation or liability in favor of third persons such as Sps. Mamaril.

  4. The contractual relationship between the parties is one of lease.

  5. BSP is not liable for the loss suffered by Sps. Mamaril as it was caused by the negligence of the security guards, who were employed by AIB Security Agency, and not BSP.

  6. The exculpatory clause contained in the BSP issued parking ticket is not void and is binding between the parties as the contract is not against public policy. Sps. Mamaril have been leasing BSP's parking space for a long time without objection to the terms of the contract.

  7. Sps. Mamaril are not entitled to damages as they failed to provide sufficient proof of the amount of damages sustained.

  8. The instant petition is denied. The Decision and Resolution of the Court of Appeals are affirmed.

PRINCIPLES:

  • Article 20 of the Civil Code provides that a person who causes damage to another, contrary to law, shall indemnify the latter.

  • Article 2176 of the Civil Code imposes liability on whoever causes damage to another through fault or negligence.

  • Proximate cause is the cause that produces the injury or loss without which the result would not have occurred.

  • Vicarious liability does not apply to clients or customers of a security agency for the acts of security guards employed by the agency.

  • Agency is based on representation, and a pure principal-client relationship does not establish an agency relationship.

  • Contracts take effect only between the parties, their assigns, and heirs, unless otherwise provided by law. Stipulations in favor of a third person must meet certain requisites to be enforceable.

  • The principle of relativity of contracts dictates that only the parties to a contract are bound by its terms and are entitled to claim any rights or benefits under it.

  • The act of parking a vehicle in a garage, upon payment of a fixed amount, constitutes a lease.

  • The lessor is obliged to deliver the leased property in a condition fit for use, make necessary repairs, and maintain the lessee in peaceful and adequate enjoyment of the lease.

  • The lessor is not liable for a mere act of trespass caused by a third person on the use of the leased property, but the lessee has a direct action against the intruder.

  • Contracts of adhesion are binding and enforceable if not against public policy, and a party who enters into it is free to reject the stipulations if they find them unfavorable.

There are no specific legal principles or doctrines mentioned in this excerpt of the case.