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GR NO. L-9605, September 30, 1957: Erezo V Jepte

The defendant, Jepte, was the registered owner of a truck that collided with and injured the plaintiff, Erezo, while being driven by another person. Jepte claimed he was no longer the actual owner at the time of the accident. The court ruled that Jepte, as the registered owner, is primarily responsible for damages to Erezo, but has the right to seek indemnification from the real owner for any damages he has to pay. Motor vehicle registration is intended to easily identify responsible parties in accidents, and a registered owner cannot avoid liability by claiming someone else is the actual owner.
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0% found this document useful (0 votes)
295 views1 page

GR NO. L-9605, September 30, 1957: Erezo V Jepte

The defendant, Jepte, was the registered owner of a truck that collided with and injured the plaintiff, Erezo, while being driven by another person. Jepte claimed he was no longer the actual owner at the time of the accident. The court ruled that Jepte, as the registered owner, is primarily responsible for damages to Erezo, but has the right to seek indemnification from the real owner for any damages he has to pay. Motor vehicle registration is intended to easily identify responsible parties in accidents, and a registered owner cannot avoid liability by claiming someone else is the actual owner.
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being properly registered for the current year, but that dealers
Erezo v Jepte in motor vehicles shall furnish the Motor Vehicles Office a
GR NO. L-9605, September 30, 1957 report showing the name and address of each purchaser of
motor vehicle during the previous month and the
manufacturer's serial number and motor number.

Registration is required not to make said registration the


FACTS: operative act by which ownership in vehicles is transferred, as
Defendant-appellant is the registered owner of a six by six in land registration cases, because the administrative
truck bearing. On August, 9, 1949, while the same was being proceeding of registration does not bear any essential relation
driven by Rodolfo Espino y Garcia, it collided with a taxicab at to the contract of sale between the parties, but to permit the
the intersection of San Andres and Dakota Streets, Manila. As use and operation of the vehicle upon any public
the truck went off the street, it hit Ernesto Erezo and another,
and the former suffered injuries, as a result of which he died. The main aim of motor vehicle registration is to identify the
owner so that if any accident happens, or that any damage or
The driver was prosecuted for homicide through reckless injury is caused by the vehicles on the public highways,
negligence. The accused pleaded guilty and was sentenced to responsibility therefore can be fixed on a definite individual, the
suffer imprisonment and to pay the heirs of Ernesto Erezo the registered owner.
sum of P3,000. As the amount of the judgment could not be
enforced against him, plaintiff brought this action against the A registered owner who has already sold or transferred a
registered owner of the truck, the defendant-appellant. vehicle has the recourse to a third-party complaint, in the same
action brought against him to recover for the damage or injury
The defendant does not deny at the time of the fatal accident done, against the vendee or transferee of the vehicle.
the cargo truck driven by Rodolfo Espino y Garcia was
registered in his name. He, however, claims that the vehicle Were a registered owner allowed to evade responsibility by
belonged to the Port Brokerage, of which he was the broker at proving who the supposed transferee or owner is, it would be
the time of the accident. He explained, and his explanation was easy for him, by collusion with others or otherwise, to escape
corroborated by Policarpio Franco, the manager of the said responsibility and transfer the same to an indefinite
corporation, that the trucks of the corporation were registered person, or to one who possesses no property with which to
in his name as a convenient arrangement so as to enable the respond financially for the damage or injury done. A victim of
corporation to pay the registration fee with his backpay as a recklessness on the public highways is usually without means
pre-war government employee. Franco, however, admitted that to discover or identify the person actually causing the injury or
the arrangement was not known to the Motor Vehicle Office. damage. He has no means other than by a recourse to the
registration in the Motor Vehicles Office to determine who is
The trial court held that as the defendant-appellant represented the owner. The protection that the law aims to extend to him
himself to be the owner of the truck and the Motor Vehicle would become illusory were the registered owner given the
Office, relying on his representation, registered the vehicles in opportunity to escape liability by disproving his ownership. If
his name, the Government and all persons affected by the the policy of the law is to be enforced and carried out, the
representation had the right to rely on his declaration of registered owner should be allowed to prove the contrary to the
ownership and registration. It, therefore, held that the prejudice of the person injured that is, to prove that a third
defendant-appellant is liable because he cannot be permitted person or another has become the owner, so that he may
to repudiate his own declaration. thereby be relieved of the responsibility to the injured person.
ISSUE:
Whether or not Jepte should be liable to Erezo for the injuries
occasioned to the latter because of the negligence of the driver
even if he was no longer the owner of the vehicle at the time of
the damage - YES

RULING:

THE REGISTERED OWNER, THE DEFENDANT-


APPELLANT HEREIN, IS PRIMARILY RESPONSIBLE FOR
THE DAMAGE CAUSED TO THE VEHICLE OF THE
PLAINTIFF-APPELLEE, BUT HE (DEFENDANT-
APPELLANT) HAS A RIGHT TO BE INDEMNIFIED BY THE
REAL OR ACTUAL OWNER OF THE AMOUNT THAT HE
MAY BE REQUIRED TO PAY AS DAMAGE FOR THE
INJURY CAUSED TO THE PLAINTIFF-APPELLANT.

The Revised Motor Vehicle Law provides that no vehicle may


be used or operated upon any public highway unless the same
is properly registered. Not only are vehicles to be registered
and that no motor vehicles are to be used or operated without

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