Case Digest: Benedicto v. Intermediate Appellate Court, 187 SCRA 547, G.R. No. 70876

Benedicto v. Intermediate Appellate Court, 187 SCRA 547, G.R. No. 70876, 19 July 1990.

Subject: Transportation Law

FACTS

The petitioner, Ma. Luisa Benedicto, was the registered owner of a cargo truck that was used to transport sawn lumber from Greenhills Wood Industries Company, Inc. to Blue Star Mahogany, Inc. The driver of the truck, Virgilio Licuden, was not an employee of Benedicto, but of Benjamin Tee, to whom Benedicto had sold the truck on an installment basis.

The truck never arrived at Blue Star Mahogany, and the sawn lumber was never delivered. Greenhills Wood Industries filed a civil case against Benedicto for the recovery of the value of the lost sawn lumber.

Benedicto denied liability, arguing that she was no longer the owner of the truck at the time of the loss. However, the trial court and the Court of Appeals both ruled in favor of Greenhills Wood Industries.

ISSUE

Whether or not Benedicto, being the registered owner of the carrier, should be held liable for the value of the undelivered or lost sawn lumber.

RULING

Yes.

Under the law, the registered owner is liable for the consequences from the operations of the carrier, even though the specific vehicle involved may already have been transferred to another person. This doctrine rests upon the principle that in dealing with vehicles registered under the Public Service Law, the public has the right to assume that the registered owner is the actual or lawful owner thereof.

In this case, it would be very difficult and often impossible as a practical matter, for members of the general public to enforce the rights of action that they may have for injuries inflicted by the vehicles being negligently operated if they should be required to prove who the actual owner is. Therefore, Greenhills is not required to go beyond the vehicle’s certificate of registration to ascertain the owner of the carrier.