Equitable Leasing Corporation vs. Lucita Suyom, Marissa Enano, Myrna Tamayo and Felix Oledan [G.R. No.

143360, 5 September 2002, 388 SCRA 445]

Facts:

A tractor driven by Raul Tutor rammed into a house-cum-store in Tondo, Manila. Part of the house was destroyed. Two people died and four were injured. Tutor was convicted of reckless imprudence resulting in multiple homicide and multiple physical injuries.

Verification with the Land Transportation Office revealed that the registered owner of the tractor was Equitable Leasing Corporation who leased it to Edwin Lim. The relatives of the victims filed a civil case for damages. The Regional Trial Court ruled against Equitable and ordered it to pay damages to the victims relatives. Upon Equitables appeal, the Court of Appeals sustained the RTC. Equitable filed a petition for review with the Supreme Court. Issue: Whether Equitable Leasing is liable for damages

Held/Ratio: Yes, Equitable Leasing is liable. The petition is denied and the CA decision is affirmed. As the registered owner of the tractor, Equitable Leasing is liable for the acts of Raul Tutor even if he was actually the employee of Equitables former lessee, Ecatine Corporation, who became the actual owner of the tractor by virtue of a deed of sale not registered with the LTO. Regardless of sales made of a motor vehicle, the registered owner is the lawful operator insofar as the public and third persons are concerned; consequently, it is directly and primarily responsible for the consequences of its operation. In the eyes of the law, the owner/operator of record is the employer of the driver, the actual owner/operator being considered as merely the agent of the registered owner/operator. The principle applies even if the registered owner of any vehicle does not use it for public service. The main aim of motor vehicle registration is to identify the owner so that if any accident happens, or any damage or injury is caused by the vehicle, responsibility can be fixed on a definite individual, the registered owner. Failure to register the deed of sale should not prejudice victims, who have the right to rely on the principle that the registered owner is liable for damages caused by the negligence of the driver. Equitable Leasing cant hide behind the allegation that Tutor was Ecatine Corps employee, because it will prevent victims from recovering their

loss on the basis of Equitables inaction in failing to register the sale. The non-registration is Equitables fault, which should face the legal consequences thereof.