G.R. No. 167546 ; July 17, 2009
SONNY ROMERO Y DOMINGUEZ, Petitioner, vs. PEOPLE OF THE PHILIPPINES, et al., Respondents.

FACTS

On April 1, 1999, a head-on collision occurred between a JC Liner bus driven by petitioner Sonny Romero and an Apego taxi along a highway in Camarines Sur. The accident resulted in multiple fatalities, serious injuries, and property damage. Consequently, petitioner was charged with reckless imprudence resulting in multiple homicide, multiple serious physical injuries, and damage to property before the Municipal Trial Court (MTC).
After trial, the MTC acquitted petitioner of the criminal charge, finding that the prosecution failed to prove his guilt beyond reasonable doubt. The court, however, held him civilly liable and ordered him to pay damages to the victims’ heirs. Petitioner appealed, arguing that his acquittal should absolve him of civil liability. The Regional Trial Court (RTC) and the Court of Appeals (CA) affirmed the MTC’s decision. Petitioner now elevates the case, reiterating his claim and additionally arguing that the taxi driver was not the registered driver at the time of the accident.

ISSUE

Whether the acquittal of the accused in a criminal case for reckless imprudence necessarily extinguishes his civil liability arising from the same act.

RULING

No. The Supreme Court denied the petition, affirming that acquittal does not automatically extinguish civil liability. The legal logic is anchored on the distinction between criminal and civil liability, and the quantum of evidence required for each. Under the Rules of Court, the extinction of the penal action does not carry with it the extinction of the civil action, unless the court’s final judgment explicitly declares that the act or omission from which the civil liability might arise did not exist.
In this case, the MTC acquitted petitioner based on reasonable doubt, as it could not ascertain with moral certainty the wanton and reckless manner of his driving. Crucially, the court did not find that the act from which civil liability might arise was non-existent. The acquittal was due to the prosecution’s failure to meet the high standard of proof beyond reasonable doubt required in criminal cases. However, civil liability, which arises from quasi-delict or culpa aquiliana, requires only a preponderance of evidence. The MTC, RTC, and CA uniformly found sufficient evidence to establish petitioner’s negligence by this lower standard, warranting the award of damages. The Court upheld this finding, emphasizing it does not re-examine factual determinations absent exceptional circumstances, none of which were present. Thus, petitioner was correctly held civilly liable despite his acquittal.