Case Digest: BA Finance v. Court of Appeals, 215 SCRA 715, G.R. No. 98275

BA Finance v. Court of Appeals, 215 SCRA 715, G.R. No. 98275, 13 November 1992.

Subject: Transportation Law

FACTS

On March 6, 1983, an accident occurred involving BA FINANCE CORPORATION Isuzu ten-wheeler truck then driven by an employee of Lino Castro.

Rogelio Villar y Amare, the driver of the Isuzu truck, was at fault when the mishap occurred in as much as he was found guilty beyond reasonable doubt of reckless imprudence resulting in triple homicide with multiple physical injuries with damage to property of the RTC at Malolos, Bulacan. Petitioner was adjudged liable for damages in as much as the truck was registered in its name during the incident in question.

Petitioner asseverates that it should not have been haled to court and ordered to respond for the damage in the manner arrived at by both the trial and appellate courts since the complaint lodged by the plaintiffs would indicate the petitioner was not the employer of the negligent driver who was under the control and supervision of Lino Castro at the time of the accident, apart from the fact that the Isuzu truck was in the physical possession of Rock Component Philippines by virtue of the lease agreement.

ISSUE

Whether or not petitioner can be held responsible to the victim albeit the truck was leased to Rock Component Philippines when the incident occurred.

RULING

Yes, BA Finance Corporation is liable.

The Revised Motor Vehicle Law (Act No. 3992, as amended) provides that the vehicle may be used or operated upon any public highway unless the same is properly registered. It has been stated that the system of licensing and the requirement that each machine must carry a registration number, conspicuously displayed, is one of the precautions taken to reduce the danger of injury of pedestrians and other travelers from the careless management of automobiles, and to furnish a means of ascertaining the identity of persons violating the laws and ordinances, regulating the speed and operation of machines upon the highways.

Registration is required not to make said registration the operative act by which ownership in vehicles is transferred, as in land registration cases, because the administrative proceeding of registration does not bear any essential relation to the contract of sale between the parties but to permit the use and operation of the vehicle upon any public highway, the main aim of motor vehicle registration is to identify the owner so that if any accident happens, or that any damage or injury is caused by the vehicle on the public highways, responsibility therefor can be fixed on a definite individual, the registered owner.

In this case, the petitioner being the registered owner of the vehicle is liable. The law, with its aim and policy in mind, does not relieve the registered owner directly of the responsibility that the law fixes and places upon him as an incident or consequence of registration. Were a registered owner allowed to evade responsibility by proving who the supposed transferee or owner is, it would be easy for him, by collusion with others or otherwise, to escape said responsibility and transfer the same to an indefinite person, or to one who possesses no property with which to respond financially for the damage or injury done.