Case Doctrines: 

● When a man and woman live 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 (Article 144, New Civil Code). The co-ownership contemplated, however, requires that both parties are not in anyway incapacitated to contract marriage.

● 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.

Facts: Eugenio Jose was the registered owner and operator of the passenger jeepney involved in an accident of collision with a freight train of the Philippine National Railways that took place on November 23, 1969 which resulted in the death to seven (7) and physical injuries to five (5) of its passengers. At the time of the accident, Eugenio Jose was legally married to Socorro Ramos but had been cohabiting with defendant-appellant, Rosalia Arroyo, for sixteen (16) years in a relationship akin to that of husband and wife. The trial court rendered a decision in a civil case for damages arising from the vehicular accident, ordering Eugenio Jose and Rosalia Arroyo to jointly and severally pay damages to the victims of the accident. 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 Jose, a legally married man.

Issues: 

1. Whether or not Article 144 of the Civil Code (now Article 148 of FC) is applicable in a case where one of the parties in a common-law relationship is incapacitated to marry.

 2. Whether or not Rosalia can be held jointly and severally liable for damages with Eugenio.

Held: 

1. No. The co-ownership contemplated in Article 144 of the Civil Code requires that the man and the woman living together must not in any way be incapacitated to contract marriage. Since Eugenio Jose is legally married to Socorro Ramos, there is an impediment for him to contract marriage with Rosalia Arroyo. 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 his legal wife. There is therefore no basis for the liability of Arroyo 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)