Juaniza vs.

Jose
Facts:

Eugenio Jose was the registered owner and operator of the passenger jeepney. In 1969, said jeepney collided
with a freight train of the Philippine National Railways, resulting to the death of 7 and physical injuries to 5 of its
passengers. At the time of the accident, Eugenio was legally married to Socorro Ramos but had been cohabiting
with Rosalia Arroyo for 16 years. The trial court rendered a decision ordering Eugenio and Rosalia to jointly and
severally pay damages to the victims of the accident. The lower court based her liability on Article 144 of the Civil
Code which reads: "When a man and woman living together as husband and wife, but they are not married, or
their marriage is void from the beginning, the property acquired by either or both of them through their work or
industry or their wages and salaries shall be governed by the rules on co-ownership." Rosalia claims that it was
error for the trial court to consider her a co-owner of the said jeepney, just because she had cohabited for many
years as wife of Eugenio.

Issues:
1. Were Eugenio and Rosalia co-owners of the jeepney?
2. Can Rosalia be held jointly and severally liable for damages with Eugenio?

Held:

1. No. Article 144 of the Civil Code pertains only to those common law relationships where neither of the parties
are suffer from any legal impediment to marry. Since Eugenio is legally married to Socorro Ramos, there is an
impediment for him to contract marriage with Rosalia. Under the aforecited provision of the Civil Code, Arroyo
cannot be a co-owner of the jeepney. The jeepney belongs to the conjugal partnership of Jose and Socorro. There
is therefore no basis for the liability of Rosalia for damages arising from the death of, and physical injuries suffered
by, the passengers of the jeepney which figured in the collision.

2. No. It is settled in our jurisprudence that only the registered owner of a public service vehicle is responsible for
damages that may arise from consequences incident to its operation, or maybe caused to any of the passengers
therein. (Juaniza vs Eugenio Jose, G.R. Nos. L-50127-28. March 30, 1979)

Juaniza vs Jose
GR. No. L50127-28, March 30, 1979

FACTS:

Eugenio Jose, a registered owner and operator of the passenger jeepney involved in an accident of collision with a
freight train of the PNR that took place in November 1969 resulted in the 7 deaths and 5 physical injuries of its
passengers. That time, Eugenio was married to Socorro but had been cohabiting with Rosalia Arroyo, defendant-
appellant for 16 years as husband and wife. Trial court decision rendered them jointly and severally liable to pay
damages to the heir of the deceased, Victor Juaniza. A motion was prayed for by Rosalia for the decision to be
reconsidered.

ISSUE: WON Eugenio and Rosalia are co-owners of the jeepney.

HELD:
The co-ownership provided in Article 147 applied only when the parties are not incapacitated to marry. Hence, the
jeepney belongs to the conjugal partnership with the lawful wife. The common-law wife not being the registered
owner cannot be held liable for the damages caused by its operation. There is therefore no basis for her liability in
the damages arising from the death of and physical injuries suffered by the passengers.