TORTS AND DAMAGES

What is the so-called registered-

owner-of-the-vehicle rule in
vehicular mishaps?
The registered owner of the vehicle rule means that registered owner
of any vehicle, even if not used for public service, would primarily be
responsible to the public or to third persons for injuries caused by the
latter while the vehicle was being driven on the highways or streets.
In Erezo v. Jepte, 102 Phil 103, 108 (1957), cited in Del Carmen, Jr.
vs. Bacoy, et al., the Court advised that “the main aim of motor
vehicle registration is to identify the owner so that if any accident
happens, or that any damage or injury is caused by the vehicle on the
public highways, responsibility therefor can be fixed on a definite
individual, the registered owner. Instances are numerous where
vehicles running on public highways caused accidents or injuries to
pedestrians or other vehicles without positive identification of the
owner or drivers, or with very scant means of identification. It is to
forestall these circumstances, so inconvenient or prejudicial to the
public, that the motor vehicle registration is primarily ordained, in the
interest of the determination of persons responsible for damages or
injuries caused on public highways.”

In Filcar Transport Services v. Espinas [G.R. No. 174156, June 20,

2012], the registered owner of a motor vehicle tried to escape liability
by positing the absence of employer-employee relationship with the
offending driver. The Court was not persuaded and ruled otherwise. It
held that “x x x in case of motor vehicle mishaps, the registered owner
of the motor vehicle is considered as the employer of the tortfeasor-
driver, and is made primarily liable for the tort committed by the latter
under Article 2176, in relation with Article 2180, of the Civil Code.”

Indeed, this Court has consistently been of the view that it is for the
better protection of the public for both the owner of record and the
actual operator to be adjudged jointly and severally liable with the
driver. As aptly stated by the appellate court, “the principle of holding
the registered owner liable for damages notwithstanding that
ownership of the offending vehicle has already been transferred to
another is designed to protect the public and not as a shield on the
part of unscrupulous transferees of the vehicle to take refuge in, in
order to free itself from liability arising from its own negligent act. R
Transport Corporation v. Yu [G.R. No. 174161, February 18, 2015]