Philippine Rabbit Bus Lines, Inc. and its driver Felix Pangalangan filed a complaint against Phil-American Forwarders, Inc. for damages caused by one of its drivers, Fernando Pineda, who recklessly bumped their bus. Archimedes Balingit, the manager of Phil-American Forwarders, Inc., moved for dismissal of claims against him. The lower court granted dismissal. The Supreme Court affirmed, holding that as a manager, Balingit was not considered an "owner" or "employer" under Article 2180, and could not be held liable for the acts of Pineda.
Philippine Rabbit Bus Lines, Inc. and its driver Felix Pangalangan filed a complaint against Phil-American Forwarders, Inc. for damages caused by one of its drivers, Fernando Pineda, who recklessly bumped their bus. Archimedes Balingit, the manager of Phil-American Forwarders, Inc., moved for dismissal of claims against him. The lower court granted dismissal. The Supreme Court affirmed, holding that as a manager, Balingit was not considered an "owner" or "employer" under Article 2180, and could not be held liable for the acts of Pineda.
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Torts
Original Title
Philippine Rabbit Bus Lines vs Phil-American Forwarders
Philippine Rabbit Bus Lines, Inc. and its driver Felix Pangalangan filed a complaint against Phil-American Forwarders, Inc. for damages caused by one of its drivers, Fernando Pineda, who recklessly bumped their bus. Archimedes Balingit, the manager of Phil-American Forwarders, Inc., moved for dismissal of claims against him. The lower court granted dismissal. The Supreme Court affirmed, holding that as a manager, Balingit was not considered an "owner" or "employer" under Article 2180, and could not be held liable for the acts of Pineda.
Philippine Rabbit Bus Lines, Inc. and its driver Felix Pangalangan filed a complaint against Phil-American Forwarders, Inc. for damages caused by one of its drivers, Fernando Pineda, who recklessly bumped their bus. Archimedes Balingit, the manager of Phil-American Forwarders, Inc., moved for dismissal of claims against him. The lower court granted dismissal. The Supreme Court affirmed, holding that as a manager, Balingit was not considered an "owner" or "employer" under Article 2180, and could not be held liable for the acts of Pineda.
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Philippine Rabbit Bus Lines, Inc. vs Phil-American Forwarders, Inc.
G.R. No. L-25142 March 25, 1975
Doctrine: The terms "employers" and "owners and managers of an establishment or enterprise" used in article 2180 of the Civil Code do not include the manager of a corporation. It may be gathered from the context of article 2180 that the term "manager" is used in the sense of "employer". Facts: Philippine Rabbit Bus Lines, Inc. and Felix Pangalangan filed a complaint against PhilAmerican Forwarders, Inc., Archimedes J. Balingit and Fernando Pineda. It was alleged that Pineda drove recklessly a freight truck, owned by Phil-American Forwarders, Inc., and bumped the bus driven by Pangalangan, owned by Philippine Rabbit Bus Lines, Inc. As a result of the bumping, Pangalangan suffered injuries and the bus was damaged and could not be used for seventy-nine days, thus depriving the company of earnings. Balingit was the manager of Phil-American Forwarders, Inc. meanwhile, Balingit moved for the dismissal of the case against him on the ground that that the bus company and the bus driver had no cause of action against him. The lower court then granted Balingits motion. Both the Bus Company and Pangalangan appealed. Issue: WON Balingit, manager of Phil-American, is liable for the acts of Pineda under Article 2180 of the Civil Code. Ruling: No, the SC held that no tortious or quasi-delictual liability can be fastened on Balingit as manager of Phil-American Forwarders, Inc., in connection with the vehicular accident already mentioned because he himself may be regarded as an employee or dependiente of his employer, Phil-American Forwarders, Inc.