CIVIL LAW > XI. QUASI-DELICTS > B. The Tortfeasor > 1. The Direct Tortfeasor > b. Juridical Persons

Under Philippine civil law, juridical persons may be held liable as direct tortfeasors for quasi-delicts. Juridical persons, as defined under Article 44 of the Civil Code, include corporations, partnerships, associations, and entities to which the law grants a juridical personality separate and distinct from that of their members. Their liability in quasi-delicts arises when tortious acts or omissions causing damage to another are committed by their employees, agents, or representatives acting within the scope of their duties and authority.

1. General Principle of Liability of Juridical Persons

Juridical persons are liable under the doctrine of vicarious liability (also known as respondeat superior), which is enshrined in Article 2180 of the Civil Code. The article provides that employers (whether natural or juridical persons) are responsible for the damages caused by their employees in the performance of their duties.

2. Legal Basis

Article 2176, Civil Code: The foundational provision on quasi-delicts states that any person (natural or juridical) who, by act or omission, causes damage to another through fault or negligence, without a pre-existing contractual relation, is liable for such damage.
Article 2180, Civil Code: This article specifically extends liability for quasi-delicts to employers and those with juridical personalities, emphasizing their obligation to exercise diligence in the selection and supervision of their employees.

3. Elements of Liability

For a juridical person to be held liable as a direct tortfeasor, the following must be established:

Damage or Injury – The plaintiff must have suffered an actual injury or damage.
Fault or Negligence – The tortious act or omission causing the injury was committed through fault or negligence.
Agency or Employment Relationship – The wrongful act must have been committed by an individual (e.g., an employee, agent, or representative) acting within the scope of their duties or authority for the juridical person.
Causal Connection – There must be a direct causal link between the tortious act or omission and the injury suffered.

4. Scope of Liability

Juridical persons are directly liable when the negligence or fault arises from:
- The act of their employees (vicarious liability).
- Their own negligence, such as in the supervision of employees, maintenance of facilities, or in fulfilling statutory obligations.
Employer’s Fault in Supervision/Selection: Employers may be directly liable if it can be proven that they were negligent in:
- Hiring individuals with known propensities for misconduct.
- Failing to provide adequate training, supervision, or oversight.

5. Application in Corporate Settings

Corporate Acts: When a corporation or juridical person’s board of directors, officers, or agents act negligently or commit a wrongful act, the entity itself may be held liable if the act was within the scope of their authority.
Individual vs. Corporate Liability: While the individuals involved may also be sued in their personal capacities, the juridical person is primarily liable when the act is performed in the course of the corporate entity’s business.

6. Defenses Available to Juridical Persons

To escape liability, juridical persons may invoke the following defenses:

Exercise of Diligence (Article 2180, Civil Code): Proving that they exercised the necessary diligence in the selection and supervision of employees.
Lack of Agency or Employment Relationship: Establishing that the tortfeasor acted outside the scope of their employment or authority.
Absence of Fault or Negligence: Demonstrating that the damage was caused solely by the negligence or deliberate act of another party (e.g., force majeure or acts of third persons).

7. Examples in Philippine Jurisprudence

Filamer Christian Institute v. IAC (G.R. No. 75112, August 17, 1992): A school was held vicariously liable for a driver’s negligence in causing a traffic accident while performing duties related to his employment. The court ruled that the school failed to exercise proper diligence in supervising its employees.
Metro Manila Transit Corp. v. CA (G.R. No. 100897, April 30, 1993): The transit company was held liable for injuries caused by its driver, who was acting within the scope of his employment.
Amadora v. CA (G.R. No. L-47745, April 15, 1988): A school was held liable for the death of a student due to its negligence in providing proper safety measures within its premises.

8. Extent of Liability

Compensatory Damages: Juridical persons may be required to compensate the injured party for actual damages suffered, including medical expenses, lost income, and property damage.
Moral and Exemplary Damages: In cases of gross negligence or bad faith, juridical persons may also be ordered to pay moral and exemplary damages.
Subrogation of Liability: Juridical persons may seek indemnification from the direct tortfeasor (e.g., employee) if proven that the latter acted beyond their authority or committed the wrongful act willfully.

9. Statutory and Regulatory Framework

Apart from the Civil Code, other laws may impose quasi-delict liability on juridical persons:

Revised Corporation Code (R.A. 11232): Holds corporations liable for wrongful acts done by their agents within the bounds of their corporate authority.
Special Laws: Statutory obligations, such as those under environmental laws or consumer protection statutes, may give rise to additional liabilities for quasi-delicts when breached.

Conclusion

Juridical persons, though artificial entities, bear the same responsibility as natural persons for wrongful acts committed by their representatives within the scope of employment or authority. Their liability under quasi-delicts is rooted in their legal obligation to ensure that their employees and agents perform their duties without causing harm. The law thus holds them accountable to foster diligence, ensure justice for victims, and promote social responsibility in corporate and institutional settings.