Villanueva vs.

Domingo
G.R. NO. 144274
September 20, 2004

CORONA, J.
Facts:
Priscilla Domingo is the registered owner of a silver Mitsubishi Lancer Car with co-
respondent Leandro Luis Domingo as authorized driver. The petitioner, Nostradamus
Villanueva was then the registered “owner” of a green Mitsubishi Lancer.
In 1991, the green Mitsubishi Lancer driven by Renato Dela Cruz Ocfemia darted directly into
the path of the silver car, thus hitting and bumping its left front portion. The driver was
found to be driving with an expired license and was positive for alcoholic breath.
The petitioner claims that he was no longer the owner of the car at the time of the incident
because it was swapped with another car.
Issue:
Can the registered owner of a motor vehicle be held liable for damages arising from a
vehicular accident involving his vehicle while being operated by the employee of its buyer
without the latter’s consent and knowledge?
Ruling:

Yes. The Supreme Court has constantly ruled that the registered owner of a vehicle is mainly
responsible to the public and third persons while it is being operated.

This is based on that when dealing with vehicles registered under the Public Service Law, the
community has the right to presume that the registered owner is the actual owner of the
said vehicle, as it would be challenging to impose the actions that people may have for
injuries caused to them by the vehicles being carelessly driven if the public should be
mandated to prove the actual owner.
The Court further states that the registered owner may recover whatever amount he had
paid by virtue of his liability to third persons from the person to whom he had sold the
vehicle.
Furthermore, the registered owner of any means of transportation, even if not used for a
public service, must primarily be accountable to the community or to third persons for
injuries caused by the latter while the vehicle is being driven on the highways or streets.