In Greenstar Express, Inc. vs. Universal Robina Corporation, the Supreme Court addressed the extent of an employer’s liability for the negligent acts of an employee driving a company-owned vehicle. The Court ruled that the employer, Universal Robina Corporation (URC), was not liable for the damages caused by its employee because the employee was not acting within the scope of his employment at the time of the accident. This decision underscores the importance of establishing a direct link between an employee’s actions and their assigned tasks for employer liability to arise.

Whose Fault Was It? Examining Negligence and Scope of Employment in a Highway Collision

The case arose from a collision between a Greenstar Express bus and a Universal Robina Corporation (URC) van on February 25, 2003. The URC van, driven by Renante Bicomong, collided with the bus driven by Fruto Sayson, Jr., resulting in Bicomong’s death. Greenstar Express, Inc. (Greenstar) and Sayson filed a complaint against URC and its subsidiary, Nissin Universal Robina Corporation (NURC), seeking damages based on negligence. The central issue was whether URC could be held liable for Bicomong’s actions, given that the accident occurred on a declared national holiday and Bicomong was using the vehicle for personal purposes.

The Regional Trial Court (RTC) dismissed the complaint, finding that Bicomong was not acting within the scope of his employment at the time of the accident. The Court of Appeals (CA) affirmed this decision, emphasizing that for an employer to be liable under Article 2180 of the Civil Code, the employee must have caused the damage while performing assigned tasks. The appellate court highlighted that Bicomong was on his way home on a holiday, using a vehicle not officially assigned to him, thus not acting within the scope of his employment.

Petitioners, Greenstar and Sayson, argued that URC should be held liable under Articles 2176, 2180, and 2185 of the Civil Code, asserting that Bicomong’s negligence was the proximate cause of the accident. They contended that Bicomong’s act of driving on the opposite lane constituted a traffic violation, raising a presumption of negligence. They also claimed that URC failed to prove that Bicomong was not performing his official duties and that URC should be held liable as the registered owner of the van. Respondents, URC and NURC, countered that the collision occurred on a holiday while Bicomong was using the vehicle for personal purposes, absolving them of liability. They also argued that Sayson was negligent in operating the bus, having the last clear chance to avoid the collision.

The Supreme Court denied the petition, affirming the CA’s decision. The Court based its ruling on the principle that an employer is only liable for the negligent acts of an employee when those acts are committed within the scope of their assigned tasks. The Court cited Caravan Travel and Tours International, Inc. v. Abejar, which harmonized Article 2180 of the Civil Code with the registered-owner rule, stating that the plaintiff must first establish that the employer is the registered owner of the vehicle. Once ownership is proven, a disputable presumption arises that the requirements of Article 2180 have been met, shifting the burden of proof to the defendant to show that no liability under Article 2180 has arisen. This can be done by proving that there was no employment relationship, that the employee acted outside the scope of their assigned tasks, or that the employer exercised due diligence in the selection and supervision of the employee.

In this case, the Court found that URC successfully overcame the presumption of negligence by demonstrating that Bicomong was not performing his work at the time of the collision. The accident occurred on a declared national holiday, and Bicomong was using a vehicle not officially assigned to him for a personal purpose: going home to Quezon province. The Court noted that Bicomong’s official duties were limited to the Cavite area, and he had no official business in either Quezon or Laguna, where the collision occurred.

Furthermore, the Court pointed out that the evidence suggested that Sayson, the bus driver, could have avoided the collision had he exercised due care and prudence. Sayson saw the URC van traveling fast on the shoulder of the opposite lane but did not take necessary precautions such as reducing speed or adopting a defensive stance. The Court emphasized that common carriers are required to exercise the highest degree of diligence for the safety of their passengers, and Sayson failed to meet this standard. The Court invoked the doctrine of last clear chance, stating that Sayson had the last clear opportunity to avoid the collision but failed to do so.

The Supreme Court emphasized that the registered owner rule does not automatically impose liability; instead, it creates a presumption that can be overcome by evidence showing the employee was acting outside the scope of their employment. The decision underscores the importance of determining the scope of employment when assessing an employer’s liability for the negligent acts of their employees. It also highlights the responsibility of drivers, particularly those operating common carriers, to exercise due care and take necessary precautions to avoid accidents.

FAQs

What was the key issue in this case?	The key issue was whether an employer is liable for the negligent acts of an employee when the employee is not acting within the scope of their employment at the time of the accident. The Court ruled that the employer was not liable.
What is the registered owner rule?	The registered owner rule states that the registered owner of a vehicle is presumed liable for damages caused by its operation. However, this presumption can be overcome by evidence showing the driver was acting outside the scope of their employment.
What is Article 2180 of the Civil Code?	Article 2180 states that employers are liable for damages caused by their employees acting within the scope of their assigned tasks. This article was central to determining the liability of Universal Robina Corporation in this case.
What does it mean to act within the scope of employment?	Acting within the scope of employment means that the employee is performing tasks or duties assigned to them by their employer at the time of the incident. If the employee is engaged in personal activities or is off-duty, they are generally not considered to be acting within the scope of employment.
Why was URC not held liable in this case?	URC was not held liable because the employee, Renante Bicomong, was not acting within the scope of his employment at the time of the accident. He was on a holiday, using a vehicle not assigned to him, and traveling for personal reasons.
What is the doctrine of last clear chance?	The doctrine of last clear chance states that the party who had the last opportunity to avoid an accident but failed to do so is liable for the resulting damages. The Supreme Court found that Sayson had the last clear chance to avoid the collision.
What is the standard of care for common carriers?	Common carriers, such as bus companies, are required to exercise the highest degree of diligence for the safety of their passengers. This includes taking all necessary precautions to avoid accidents.
How did the court address the conflicting claims of negligence?	The court found that both parties demonstrated some degree of negligence, but the primary factor in absolving URC was the determination that their employee was outside the scope of his employment. This distinction was crucial in allocating responsibility.

This case provides valuable guidance on the complexities of employer liability in vehicle accident cases. It clarifies that the registered owner rule is not absolute and that the scope of employment remains a critical factor in determining liability. By understanding these principles, employers and employees can better assess their rights and responsibilities in similar situations.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: GREENSTAR EXPRESS, INC. VS. UNIVERSAL ROBINA CORPORATION, G.R. No. 205090, October 17, 2016