Joseph vs. Bautista

The Court held that where multiple tortfeasors are solidarily liable for a single injury, the full satisfaction of the claim by one or more of them extinguishes the obligation of all, pursuant to the principle against unjust enrichment and the nature of solidary obligation. Accordingly, the release executed by the petitioner in favor of some defendants upon payment of his claim necessarily released the remaining defendant.

Petitioner Luis Joseph was a paying passenger in a cargo truck owned by respondent Patrocinio Perez. The truck, driven by Domingo Villa, figured in an accident when it collided with a pick-up truck owned by respondents Antonio Sioson and/or Jacinto Pagarigan and driven by respondent Lazaro Villanueva. The petitioner sustained a leg fracture. He filed a complaint for damages against Perez for breach of contract of carriage and against Sioson, Pagarigan, and Villanueva for quasi-delict.

• On January 12, 1973, petitioner Luis Joseph, a paying passenger, was injured when the cargo truck he was riding in, owned by respondent Patrocinio Perez and driven by Domingo Villa, rammed a mango tree after being forced off the road by a pick-up truck owned by respondents Antonio Sioson and/or Jacinto Pagarigan and driven by respondent Lazaro Villanueva.
• Petitioner filed a complaint for damages against Perez (for breach of contract of carriage) and against Sioson, Pagarigan, and Villanueva (for quasi-delict).
• On September 27, 1974, respondents Villanueva, Cardeno, Sioson, and Pagarigan, through their insurer, paid petitioner P1,300.00 for his injuries. Petitioner executed a "release of claim" releasing these parties from liability.
• Respondent Perez subsequently moved to dismiss the case, arguing the release of the other solidary debtors inured to her benefit.
• The trial court dismissed the case, finding the release extinguished the liability of all solidary obligors.

• Petitioner maintained that his complaint embodied two separate causes of action: one for breach of contract of carriage against Perez, and another for quasi-delict against the other respondents.
• Petitioner argued that the compromise and release under the quasi-delict cause of action should not bar the continuation of the case against Perez under the contract of carriage cause of action.
• Petitioner contended that the allegations in the amended complaint holding respondents jointly and severally liable were intended to apply only in the event of execution, not to establish solidary liability from the outset.

• Respondent Perez countered that the release executed by petitioner in favor of the other respondents inured to her benefit because all respondents were solidarily liable to the petitioner.
• Respondents argued that the payment and release extinguished the entire obligation, barring further recovery by the petitioner against any of them.

• Procedural Issues: N/A
• Substantive Issues:
  • Whether the petitioner's complaint stated two separate causes of action (breach of contract and quasi-delict) such that a settlement under one should not affect the other.
  • Whether the release of some solidary debtors through payment extinguishes the liability of the remaining solidary debtor.

• Procedural: N/A
• Substantive:
  • The Court ruled that only a single cause of action existed. Because the petitioner sustained a single injury from the accident, only one cause of action arose, regardless of the different legal theories (contract and quasi-delict) invoked against different defendants. A recovery under one remedy necessarily bars recovery under the other to prevent double recovery and unjust enrichment.
  • The Court held that the respondents were solidarily liable. The full payment made by some of the solidary debtors and the subsequent release executed by the petitioner resulted in the extinguishment of the obligation and the release of all co-debtors, including respondent Perez.

• Single Cause of Action for a Single Injury — Where a single act or omission results in one injury to a person, only one cause of action arises, regardless of the number of rights violated or the different legal theories of liability that may be invoked against various defendants. The Court applied this to reject petitioner's attempt to pursue separate actions.
• Extinguishment of Solidary Obligation by Payment — Under solidary liability, payment by one of the solidary debtors extinguishes the entire obligation. The release of one co-debtor after full satisfaction of the claim necessarily releases all others. The Court applied this to bar the remaining claim against respondent Perez.

• "The singleness of a cause of action lies in the singleness of the delict or wrong violating the rights of one person. Nevertheless, if only one injury resulted from several wrongful acts, only one cause of action arises." — This passage clarifies the Court's core reasoning for finding a single cause of action.
• "The respondents having been found to be solidarity liable to petitioner, the full payment made by some of the solidary debtors and their subsequent release from any and all liability to petitioner inevitably resulted in the extinguishment and release from liability of the other solidary debtors, including herein respondent Patrocinio Perez." — This is the dispositive application of the solidary obligation principle to the facts.

• Racoma vs. Fortich, et al., 39 SCRA 520 (1971) — Cited for the definition and concept of a cause of action as the delict or wrongful act violating the plaintiff's primary right.

• Civil Code provisions on Solidary Obligations (Articles 1207, 1217) — Implicitly relied upon in ruling that payment by one solidary debtor extinguishes the entire obligation and releases the co-debtors.