The Supreme Court clarifies the extent to which an employer can be held subsidiarily liable for the criminal acts of its employees, specifically concerning civil liabilities arising from those acts. The court emphasizes that employers are not automatically responsible for every offense their employees commit while on duty. Instead, the employer’s liability hinges on whether the employee committed the offense in the actual discharge of their assigned tasks. This decision underscores the importance of determining the direct link between the employee’s duties and the wrongful act to establish employer responsibility, ensuring a fair balance between victim compensation and employer accountability.

When Bus Drivers Cause Damage: Examining Employer Liability for Employee Negligence

This case originated from a criminal case where a bus driver, Rodolfo Borja Tanio, employed by Davao ACF Bus Lines, Inc. (ACF), was found guilty of reckless imprudence resulting in serious physical injuries. Tanio’s actions caused injuries to Rogelio Ang. Consequently, the Municipal Trial Court in Cities (MTCC) awarded damages to Ang, which Tanio was unable to pay. The MTCC then issued a writ of execution against ACF, seeking to hold the company subsidiarily liable for Tanio’s debt. This prompted ACF to file a motion to quash the writ, arguing that it should not be held responsible for the damages.

The central legal question is whether ACF could be held subsidiarily liable under Article 103 of the Revised Penal Code for the damages awarded against its employee, Tanio. Subsidiary liability, as defined in Article 103, requires that the employee must have committed the offense while in the performance of their duties. This means the act must be a necessary consequence of the assigned task, not merely coincidental to the employment.

The Revised Penal Code provides the basis for subsidiary liability in Article 103, stating the conditions under which employers can be held responsible for the acts of their employees. It stipulates:

Art. 103. Subsidiary civil liability of other persons. — The subsidiary liability established in articles 101 and 102 of this Code shall also apply to employers, teachers, persons, and corporations engaged in any kind of industry for felonies committed by their servants, pupils, workmen, apprentices, or employees in the discharge of their duties.

The Supreme Court examined the decisions of the lower courts, including the MTCC, which initially sought to execute the judgment against ACF, and the Regional Trial Court (RTC) and Court of Appeals (CA), which affirmed the MTCC’s order to determine ACF’s subsidiary liability. The Supreme Court found that the MTCC had not definitively ordered the execution against ACF but had instead ordered a hearing to determine whether the requisites for subsidiary liability under Article 103 were present.

Building on this, the Supreme Court noted that grave abuse of discretion, which would warrant the intervention of a certiorari proceeding, involves errors of jurisdiction rather than errors of judgment. The Court held that even if the MTCC had erred in its judgment regarding the award of damages, such an error would not constitute grave abuse of discretion, provided the court had jurisdiction over the case. Here, ACF’s arguments centered on the supposed erroneous award of damages, which the Supreme Court deemed to be a mistake of law, not a jurisdictional error.

Furthermore, the Supreme Court emphasized the doctrine of immutability of judgments, which holds that once a judgment becomes final and executory, it can no longer be altered or modified. The MTCC’s judgment awarding damages to Ang had become final and executory because ACF did not appeal it. The Court stated:

It is established that once a judgment attains finality, it thereby becomes immutable and unalterable. Such judgment may no longer be modified in any respect, even if the modification is meant to correct what is perceived to be an erroneous conclusion of fact or law, and regardless of whether the modification is attempted to be made by the court rendering it or by the highest Court of the land.

The Court also addressed ACF’s argument that the MTCC lacked jurisdiction to render judgment on the damages because the aggregate amount exceeded the MTCC’s jurisdictional limit. The Supreme Court clarified that jurisdiction is determined by the allegations in the complaint, not by the amount ultimately awarded by the trial court. Therefore, the MTCC’s jurisdiction was valid when the case was filed, regardless of the final award.

In conclusion, the Supreme Court denied ACF’s petition, affirming the CA’s decision. The ruling reinforces the principle that employers can be held subsidiarily liable for their employees’ actions only when those actions are committed in the direct discharge of their duties. It also upholds the importance of respecting final and executory judgments and clarifies the scope of certiorari as a remedy for jurisdictional errors, not mere errors of judgment.

FAQs

What was the key issue in this case?	The key issue was whether Davao ACF Bus Lines could be held subsidiarily liable for the damages caused by its employee’s negligent actions. The court examined the conditions under which an employer can be held responsible for the civil liabilities of their employees under Article 103 of the Revised Penal Code.
What is subsidiary liability?	Subsidiary liability refers to the responsibility of an employer for the criminal acts of their employees if the employee is insolvent. This liability arises only when the employee commits the offense in the discharge of their duties.
What is grave abuse of discretion?	Grave abuse of discretion implies such capricious and whimsical exercise of judgment as is equivalent to lack of jurisdiction. It must be shown that the lower court exercised its power in an arbitrary or despotic manner.
What does the doctrine of immutability of judgments mean?	The doctrine of immutability of judgments means that once a judgment becomes final and executory, it can no longer be altered or modified. This principle ensures stability and finality in judicial decisions.
How is jurisdiction determined in a court case?	Jurisdiction is primarily determined by the allegations in the complaint filed before the court. The amount of damages ultimately awarded does not affect the court’s initial jurisdiction.
What was the MTCC’s initial action in this case?	The MTCC initially issued a writ of execution against Davao ACF Bus Lines to enforce the judgment against its employee. However, it later ordered a hearing to determine whether the requisites for subsidiary liability were met.
Why did the Supreme Court deny the petition of Davao ACF Bus Lines?	The Supreme Court denied the petition because the MTCC had not committed grave abuse of discretion and the judgment against the employee had become final. The Court also clarified that the MTCC had jurisdiction over the case.
What is the significance of Article 103 of the Revised Penal Code?	Article 103 of the Revised Penal Code establishes the subsidiary civil liability of employers for felonies committed by their employees in the discharge of their duties. It defines the scope and conditions under which employers can be held responsible.

This case serves as a crucial reminder for employers about the scope of their liability for the actions of their employees. Understanding the nuances of subsidiary liability and ensuring that employees act within the bounds of their duties is essential for mitigating potential legal risks.

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: Davao ACF Bus Lines, Inc. vs. Rogelio Ang, G.R. No. 218516, March 27, 2019