G.R. No. L-10567; November 26, 1957
ANA DIONISIO and CAROLINA ALMODOVAR, petitioners, vs. HON. CARMELINO G. ALVENDIA, Judge presiding over the Court of First Instance of Manila (Branch XVI), LA MALLORCA, LAMBERTO RAYMUNDO, GERONIMO ASUNCION and FRANCISCO LIZASO, respondents.

FACTS

On March 29, 1954, petitioners Ana Dionisio and Carolina Almodovar filed a civil action for damages in the Court of First Instance of Manila against respondents La Mallorca (a registered partnership), Lamberto Raymundo, Francisco Lizaso, and Geronimo Asuncion. The action arose from a collision on September 1953 between a taxicab owned by La Mallorca and driven by Raymundo, and a passenger jeep owned by Lizaso and driven by Asuncion, in which the petitioners were riding. The petitioners were thrown from the jeep and suffered injuries. Respondents Lizaso and Asuncion filed a motion to suspend the civil proceedings until after the criminal case for serious physical injuries through reckless imprudence filed against Raymundo and Asuncion in the Municipal Court of Manila was disposed of. This motion was initially denied. After the petitioners rested their case and the respondents began presenting evidence, motions for suspension were again filed on the same ground. The respondent Judge granted the suspension. The petitioners’ motion for reconsideration was denied. The petitioners then filed this petition, claiming the suspension order was against the law and that there was no plain, speedy, and adequate remedy.

ISSUE

Whether the respondent Court erred in suspending the proceedings in the independent civil action for damages pending the determination of the criminal case for reckless imprudence arising from the same incident.

RULING

The Supreme Court ruled in favor of the petitioners. The order suspending the hearing of the civil action was annulled and set aside, and the respondent Court was directed to resume and proceed with the trial of the civil action. The Court held that the civil action for damages arising from defamation, fraud, and physical injuries is entirely separate and distinct from the criminal action and shall proceed independently of the criminal prosecution, requiring only a preponderance of evidence. The civil responsibility arising from a crime may be determined in the criminal proceedings only if the injured party does not waive it or reserve the right to bring a separate civil action. Here, the petitioners brought an independent civil action. The owner and operator of the jeep could be held liable for breach of contract of carriage, and the owner and operator and driver of the taxicab could be held liable for tort (quasi-delict), regardless of the outcome of the criminal case. The Court found the respondents’ grounds for suspension, including avoiding an anomalous situation where a party acquitted criminally could be held civilly liable, to be groundless. The civil liability from quasi-delict is separate and distinct from civil liability arising from a crime under the Penal Code. The result of the criminal case is irrelevant to the independent civil action.