GR L 23129; (August, 1968) (Digest)
G.R. No. L-23129 August 2, 1968
ISIDRA FARAON and LUCIA DE MESA, complainants-appellants, vs. TOMAS PRIELA, accused-appellee.
FACTS
The offended parties, Isidra Faraon and Lucia de Mesa, owners of a Cadillac car, appealed the civil aspect of a decision from the Court of First Instance of Rizal. The court had acquitted Tomas A. Priela, a train engineer, of the crime of damage to property through reckless imprudence. The car was hit and destroyed by a north-bound Diesel train operated by Priela at a railroad crossing in Muntinlupa, Rizal. The incident occurred when the car’s right front wheel got stuck in a rut on the railroad tracks. Despite the driver’s efforts to move the car and Lucia de Mesa signaling the approaching train to stop, the collision happened. The trial court characterized the event as a “freak accident” and found no negligence on Priela’s part, leading to his acquittal and the denial of civil liability.
ISSUE
Whether the acquittal of the accused in the criminal action extinguishes his civil liability for damages arising from the same incident.
RULING
Yes, the acquittal extinguishes the civil liability. The Supreme Court affirmed the trial court’s decision. The Court ruled that under Rule 111, section 3(c) of the Rules of Court, the extinction of the penal action does not carry with it the extinction of the civil action, unless the final judgment declares that the fact from which the civil action might arise did not exist. In this case, the final judgment of acquittal explicitly declared that the collision was not due to any negligence on Priela’s part. Since the civil action was predicated solely on alleged negligence, which the court found non-existent, the civil responsibility was extinguished. Furthermore, the Supreme Court found no reason to disturb the trial court’s factual findings, which were based on credible testimonial and expert evidence indicating that the train could not have stopped in time due to the short distance and its speed when the obstruction became visible. The decision absolving Priela from civil liability was affirmed.