Can the owner of a private vehicle which figured in an accident be held liable under Article 2180 of the Civil Code when the said vehicle was neither driven without his consent or knowledge and by a person not employed by him?
Facts: Private respondents were on board a jeep when they met an accident with another jeep driven by Sabiniano. Private respondents thus they filed a case for damages against driver Sabiniano and owner of the jeep Duavit. Duavit admits ownership of the jeep but contends that he should not be held liable since Sabiniano is not his employee and that the jeep was taken by Sabiniano without his consent. Sabiniano categorically admitted that he took the jeep from the garage of defendant Duavit without the consent or authority of the latter. He testified further, that Duavit even filed charges against him for theft of the jeep, but which Duavit did not push through as his parents apologized to Duavit on his behalf. The trial court absolved Duavit from liability; hence, private respondents appealed.
Held: An owner of a vehicle cannot be held liable for an accident involving the said vehicle if the same was driven without his consent or knowledge and by a person not employed by him. To hold the petitioner liable for the accident caused by the negligence of Sabiniano who was neither his driver nor employee would be absurd as it would be like holding liable the owner of a stolen vehicle for an accident caused by the person who stole such vehicle. [Duavit vs CA, G.R. No. 82318, May 18, 1989]
●Absent the circumstance of unauthorized use or that the subject vehicle was stolen which are valid defenses available to a registered owner, Oscar Jr. cannot escape liability for quasi-delict resulting from his jeeps use. [Del Carmen, Jr. vs Bacoy, G.R. No. 173870, April 25, 2012]
