Both the respondent and the petitioners, Redentor Complate and employee of co-petitioner Elpidio Abaiad, are involved in the case. The respondent is a Master Sergeant of the Phil. Air Force.
While riding his bicycle to the office, Albayda was involved in a collision with a taxi driven by Completo. This resulted in severe physical injuries for Albayda, prompting him to file a complaint. The Office of the City Prosecutor recommended charges against Completo for reckless imprudence causing physical injuries. On the other hand, Completo’s counter-charge for damage to property was suggested to be dismissed. Both parties appealed the decision, but the Court of Appeals rejected their appeals citing lack of merit.
Issue: Whether the CA erred in finding that the petitioner was at fault and should be held liable for damages.
Ruling: The CA disagreed with the petitioner’s claim and removed the award of actual damages due to insufficient evidence. However, it is the responsibility of the trial court to evaluate Albaydas’ evidence, especially when inconsistencies are present. According to Article 2176 of the Civil Code, moral damages are granted in quasi-delicts resulting in physical injuries. This provision states that individuals who cause harm to others through their actions or negligence must compensate for their wrongdoing, regardless of any existing contractual relationship.
Concerning motorist negligence, it is a matter of fact. CA asserts that Abiad lacks sufficient evidence to dispute the legal assumption of negligence in hiring and supervising his driver. Employers must assess qualifications, experience, and service records when choosing potential employees. Consequently, this duty can lead to adverse outcomes. According to Article 2180 of the Civil Code, the liability stated in Article 2176 applies not only to one’s own actions or omissions but also extends to individuals for whom one bears responsibility.
Employers are accountable for covering the expenses of any damages or losses caused by their employees’ actions.
