GR 108395; (March, 1997) (Digest)
G.R. No. 108395 March 7, 1997
HEIRS OF THE LATE TEODORO GUARING, JR., petitioners, vs. COURT OF APPEALS, PHILIPPINE RABBIT BUS LINES, INC., and ANGELES CUEVAS, respondents.
FACTS
This case originated from a fatal vehicular accident on November 7, 1987, along the North Expressway in Pampanga. Involved were a Mitsubishi Lancer driven by the deceased Teodoro Guaring, Jr., a Philippine Rabbit Bus driven by respondent Angeles Cuevas, and a Toyota Cressida. The heirs of Guaring filed a civil action for damages based on quasi-delict against the bus company and its driver. They alleged the bus, attempting to overtake on the right shoulder, struck Guaring’s car, causing it to swerve into the opposite lane and collide with the oncoming Cressida. Respondents countered that Guaring’s own negligence in attempting an overtaking maneuver caused him to encroach on the opposite lane and collide with the Cressida, with his vehicle subsequently being thrown back into the bus.
The Regional Trial Court ruled in favor of the petitioners, finding the bus driver negligent and holding him and the bus company solidarily liable for damages. On appeal, the Court of Appeals reversed and dismissed the complaint. It based its decision solely on the driver’s acquittal in a prior criminal case for reckless imprudence, reasoning that the finding of no negligence in the criminal case extinguished the civil liability arising from the same act.
ISSUE
Whether the Court of Appeals erred in dismissing the civil action for damages based on quasi-delict by conclusively applying the acquittal in the criminal case.
RULING
Yes. The Supreme Court reversed the Court of Appeals and remanded the case. The appellate court erred in ruling that the acquittal in the criminal case barred the independent civil action based on quasi-delict under Article 2176 of the Civil Code. The civil action in this case was not derived from the criminal offense but was an independent suit based on culpa aquiliana. The rule that a declaration in a final judgment that the fact from which the civil action might arise did not exist extinguishes the civil liability applies only to civil actions arising from the crime itself, not to independent civil actions.
The two cases involved different parties and evidence. The petitioners in the civil case were not parties to the criminal prosecution. Furthermore, the witnesses presented in the civil case, such as the driver of the Cressida and the passenger in Guaring’s car, were different from those in the criminal case. It was fundamentally unfair to bind the petitioners to the result of a proceeding in which they did not participate. The Court of Appeals therefore erred in not evaluating the evidence presented in the civil case independently. The issues raised were factual and required proper assessment by the appellate court.