Case Digest: Benedicto vs. IAC, G.R. No. 70876

 

Benedicto vs. IAC, G.R. No. 70876, July 19, 1990

Subject: Transportation Law

FACTS

In May 1980, Greenhills, a lumber manufacturing firm, was obligated to deliver 100,000 board feet of sawn lumber to Blue Star Mahogany, Inc. in Valenzuela, Bulacan. The company's resident manager, Dominador Cruz, contracted Virgilio Licuden, the driver of a cargo truck, to transport the lumber. Licuden was charged with two invoices, one for 5,374 board feet and the other for 2,316 board feet. However, the lumber had not arrived in Valenzuela, and Blue Star's manager informed Greenhills' president. Greenhills filed criminal and civil cases against Licuden and Benedicto for estafa and recovery of the lost lumber. Benedicto denied liability, claiming she was a stranger to the contract and that the truck had been sold to Benjamin Tee. The Intermediate Appellate Court affirmed the trial court's decision, holding that since Benedicto was the registered owner of the truck, Licuden was her employee and that she should be responsible for the negligence of the driver and bear the loss of the lumber plus damages.

ISSUE

Whether or not Petitioner is liable for the value of the undelivered or lost sawn lumber.

RULING

Yes, there is no dispute that petitioner Benedicto has been holding herself out to the public as engaged in the business of hauling or transporting goods for hire or compensation. Petitioner Benedicto is, in brief, a common carrier.

The prevailing doctrine on common carriers makes the registered owner liable for consequences flowing 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 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. The registered owner is not allowed to deny liability by proving the identity of the alleged transferee.

In this case, contrary to the petitioner's claim, private respondent is not required to go beyond the vehicle's certificate of registration to ascertain the owner of the carrier. In this regard, the letter presented by the petitioner allegedly written by Benjamin Tee admitting that Licuden was his driver, had no evidentiary value not only because Benjamin Tee was not presented in court to testify on this matter but also because of the aforementioned doctrine. To permit the ostensible or registered owner to prove who the actual owner is, would be to set at naught the purpose or public policy which infuses that doctrine.