CIVIL LAW > XI. QUASI-DELICTS > B. The Tortfeasor > 2. Persons Made Responsible for Others > a. In General > iv. Nature of Liability

Under Philippine civil law, quasi-delicts are governed by Articles 2176 to 2194 of the Civil Code. The topic of liability for acts committed by others, particularly concerning the nature of liability under quasi-delicts, focuses on vicarious liability and related doctrines. This discussion will meticulously examine the nature of such liability, drawing from relevant statutes, jurisprudence, and doctrinal interpretations.

1. Legal Basis for Liability for Acts of Others

Article 2176 of the Civil Code defines a quasi-delict:

"Whoever by act or omission causes damage to another, there being fault or negligence, is obliged to pay for the damage done. Such fault or negligence, if there is no pre-existing contractual relation between the parties, is called a quasi-delict..."

However, Article 2180 imposes vicarious liability on certain persons for the acts of others:

"The obligation imposed by Article 2176 is demandable not only for one's own acts or omissions, but also for those of persons for whom one is responsible."

This codifies the principle that certain relationships create a duty of care extending to acts or omissions of others, making the responsible person liable for quasi-delicts committed by their subordinates or dependents.

2. Key Relationships That Give Rise to Vicarious Liability

Article 2180 outlines specific categories where individuals are made responsible for others:

Parents for Minor Children:
- Parents are responsible for the damages caused by their minor children who live with them.
- The liability arises from the duty of parental supervision and control.
Guardians for Wards:
- Guardians are held liable for damages caused by their wards under guardianship, especially if these acts are linked to their failure to adequately supervise.
Employers for Employees:
- Employers are liable for damages caused by their employees acting within the scope of their assigned tasks.
- Liability is grounded in the employer’s failure to exercise due diligence in the selection and supervision of their employees.
Teachers and Heads of Establishments of Arts and Trades:
- Teachers or heads of educational or technical establishments are responsible for damages caused by their students or apprentices under their custody.
- This liability is conditional upon the failure to properly supervise the students or apprentices.

3. Nature of Vicarious Liability

The liability under Article 2180 is subsidiary and presumptive, rooted in the relationship between the tortfeasor and the person held vicariously liable:

Presumption of Negligence: Vicarious liability is based on a presumption that the person responsible failed to properly supervise or exercise due diligence in the selection or oversight of the primary tortfeasor. This presumption may be rebutted by proof of due diligence.
Direct Nature of Obligation: While derivative, the liability is direct and personal in nature. The person held responsible does not merely indemnify the tortfeasor but is treated as jointly and severally liable with the tortfeasor to the injured party.
Independent Character of Liability: Liability under quasi-delict is independent of contractual relationships, as emphasized in Article 2176. This independence separates it from breaches arising under contract law.

4. Defenses Available to Persons Held Vicariously Liable

Persons held vicariously liable under Article 2180 may exculpate themselves by proving:

Due Diligence in Supervision or Selection:
- Employers may prove that they exercised due diligence in hiring and supervising employees to avoid liability.
- Parents, teachers, or guardians may also demonstrate efforts in providing adequate oversight and control.
Absence of Negligence:
- If the act of the subordinate, ward, or dependent occurred entirely without negligence or foreseeability, the principal may escape liability.
No Relationship or Lack of Authority:
- If the tortfeasor acted outside the scope of their tasks (in the case of employees) or ceased to be under the responsible person’s control, the liability may be negated.

5. Joint and Solidary Liability

Article 2194 of the Civil Code governs joint and solidary liability for quasi-delicts:

"The responsibility of two or more persons who are liable for a quasi-delict is solidary."

Persons vicariously liable under Article 2180 are solidarily liable with the primary tortfeasor. The injured party may sue either or both, and payment by one extinguishes the liability of the other to the extent of the payment.

6. Jurisprudential Applications

Filipinas Broadcasting Network, Inc. v. Ago Medical and Educational Center (2011):
- Employers were held liable for damages caused by an employee’s negligent act during the scope of employment.
- The Court emphasized the presumption of negligence in the supervision of employees.
Mercado v. Court of Appeals (1998):
- A parent was held liable for damages caused by a minor child due to lack of parental control.
PAL v. CA (1998):
- The Court reiterated that employers may avoid liability by proving due diligence in selecting and supervising employees.

7. Policy Considerations

The liability imposed on persons responsible for others balances:

Compensation for Victims: It ensures that victims of quasi-delicts have a financially viable party to recover damages from.
Encouragement of Diligence: The presumption of negligence incentivizes individuals to exercise care in their supervisory or selection duties.
Equity in Risk Allocation: Liability is placed on those who are in the best position to prevent harm.

In sum, the nature of liability under this provision is rooted in presumed fault, direct responsibility, and the solidary nature of obligations arising from quasi-delicts. This system seeks to protect injured parties while encouraging responsible behavior in relationships of authority or supervision.