16/10/2026
When a passenger bus ran over and killed Loreta J. Yu on EDSA, her husband Luisito filed a suit for damages against the driver, the actual operator (R Transport Corporation), and the registered owner (Metro Manila Transport Corporation).
MMTC pointed at R Transport, claiming it had transferred the bus under an installment sale.
R Transport pointed back at MMTC, arguing that under the Registered Owner Rule, only the registered owner can be held liable for transport accidents.
R Transport also claimed it was a diligent employer, pointing to oral testimonies from its staff about their standard hiring processes.
The case reached the Supreme Court, which rejected these arguments.
The Court clarified that the Registered Owner Rule protects injured victims, not negligent operators. It does not shield an unregistered transferee from liability under Article 2180 of the Civil Code.
Both the registered owner and the actual operator are held solidarily liable to ensure the victim's family is compensated.
Furthermore, the Court emphasized that employers cannot defeat the presumption of negligence with words alone. Companies must provide concrete documentary proofโsuch as tests, records, and training logsโto demonstrate proper selection and supervision of their drivers.
๐ R Transport Corporation v. Luisito G. Yu
G.R. No. 174161 | February 18, 2015
๐๏ธ Justice Diosdado M. Peralta