G.R. No. 70876, 19 July 1990, 187 SCRA 547
Greenhills Wood Industries – bound itself to sell and deliver to Blue Star Mahogany, Inc. 100,000 board feet of sawn lumber with the understanding that an initial delivery would be made. Greenhills resident manager in Maddela, Dominador Cruz, contracted Virgilio Licuden, the driver of a cargo truck, to transport its sawn lumber to the consignee Blue Star in Valenzuela, Bulacan; this cargo truck was registered in the name of Ma. Luisa Benedicto, the proprietor of Macoven Trucking, a business enterprise engaged in hauling freight the Manager of Blue Star called up Greenhills’ president informing him that the sawn lumber on board the subject cargo truck had not yet arrived in Valenzuela, Bulacan; because of the delay in delivery Blue Star was constrained to look for other suppliers.
Greenhill’s filed criminal case against driver Licuden for estafa and a civil case for recovery of the value of the lost sawn lumber plus damages against Benedicto. Benedicto denied liability as she was a complete stranger to the contract of carriage, the subject truck having been earlier sold by her to Benjamin Tee; but the truck had remained registered in her name because Tee have not yet fully paid the amount of the truck; be that as it may, Tee had been operating the said truck in Central Luzon from that and Licuden was Tee’s employee and not hers.
Whether or not Benedicto, being the registered owner of the carrier, should be held liable for the value of the undelivered or lost sawn lumber.
YES. The registered owner liable for consequences flowing from the operations of the carrier, even though the specific vehicle involved may already have been transferred to another person. This doctrine rests upon the principle that in dealing with vehicles registered under the Public Service Law, the public has the right to assume that the registered owner is the actual or lawful owner thereof It would be very difficult and often impossible as a practical matter, for members of the general public to enforce the rights of action that they may have for injuries inflicted by the vehicles being negligently operated if they should be required to prove who the actual owner is. Greenhills is not required to go beyond the vehicle’s certificate of registration to ascertain the owner of the carrier.
*Case digest by Allain Jay Gumela, LLB-IV, Andres Bonifacio Law School, SY 2018-2019