NOSTRADAMUS VILLANUEVA, Petitioner, v. PRISCILLA R. DOMINGO and LEANDRO LUIS R.

DOMINGO, Respondents.
G.R. NO. 144274; September 20, 2004
CORONA, J.
I. Relevant law(s):
1. Article 2180 par. 1 of the Civil Code:
The obligation imposed by Article 2176 is demandable not only for one's own
acts or omissions, but also for those of persons for whom one is responsible.

2. Section 5 (a) and (c), Act No. 3992, as amended

Section 5. All motor vehicles and other vehicles must be registered.

(a) No motor vehicle shall be used or operated on or upon any public highway of
the Philippines unless the same is properly registered for the current year in
accordance with the provisions of this Act.

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(c) Dealer's reports - The Commissioner of Land Transportation shall require

dealers to furnish him with such information and reports concerning the sale,
importation, manufacture, number of stocks, transfer or other transactions
affecting motor vehicles as may be necessary for the effective enforcement of
the provisions of this Act.

II. Factual Issue(s) and SC Ruling:

"This Court has consistently ruled that regardless of who the actual owner is of a
motor vehicle might be, the registered owner is the operator of the same with
respect to the public and third persons, and as such, directly and primarily
responsible for the consequences of its operation."

The purpose of the law for the vehicle registration is for easy identification to
prevent inconvenience and prejudice to the injured third party by one who is
unidentified.

Registered owner is not allowed to escape responsibility by proving that a third

person is the actual and real owner. However, the Registered owner has a right to be
indemnified by the real and actual owner for the amount required to pay as damage.

III. Legal Issues:

Is the Registered Owner of a Motor Vehicle liable for damages arising from a
vehicular accident that is being operated by the employee of its buyer without his
consent and knowledge?
IV. Material Facts
1. The registered owner of silver Lancer together with the driver was cruising in
moderate speed along South Superhighway. Suddenly a green Lancer darted
directly to the path of the silver Lancer, hitting and bumping its left front portion.
This resulted for the silver Lancer hit the 2 parked vehicles at the roadside and
the second hitting another parked car.
2. The traffic incident report shows that the driver of the green Lancer had expired
license and positive for alcoholic breath.
3. The registered owner of green Lancer was different from the driver of the vehicle
on the date of the accident since he has traded/swapped the vehicle for a Pajero
in Auto Palace Car Exchange.
4. Regional Trial Court (RTC) ruled against the Registered owner of the green Lancer
and ordered him to pay damages.
5. Court of Appeals upheld RTC's decision.