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HEIRS OF THE LATE DOCTOR CORAZON DIAZ-LEUS, namely, her husband, CLETO P. LEUS and children, CEZAR LEUS, DRA. CORAZON D. LEUS, JR., and CLARISSA LEUS, petitioners, vs. HERNANI MELVIDA, ALMARIO ROSAS, VICTORY LINER, INC., SPOUSES LEONISA GALI and JESUS GALI and COURT OF APPEALS, respondents.
FACTS
A tragic vehicular accident occurred on June 30, 1972, along the North Expressway in Meycauayan, Bulacan. A Plymouth car, driven by Hernani Melvida and carrying passengers including the late Dr. Corazon Diaz-Leus, was traveling northbound. Due to Melvida’s negligent and fast driving on a stormy day, the car swerved, crossed the center island, and encroached onto the southbound lane. There, it was struck by a Victory Liner bus, driven by Almario Rosas, which was traveling southbound within its proper lane. The collision resulted in the deaths of Dr. Diaz-Leus and another passenger, and injuries to others. In the subsequent criminal case for Reckless Imprudence, the trial court convicted Melvida but acquitted Rosas, finding no negligence on his part. The heirs of Dr. Diaz-Leus appealed to the Court of Appeals solely on the civil aspect, seeking to hold Rosas, his employer Victory Liner, Inc., and the owners of the Plymouth car, the Gali spouses, civilly liable for damages.
ISSUE
The core issue is whether the acquitted bus driver, Almario Rosas, along with his employer and the car owners, can be held civilly liable for damages arising from the accident.
RULING
The Supreme Court denied the petition, upholding the Court of Appeals’ decision. The legal logic is anchored on the principle that acquittal in a criminal case, when based on a finding that the accused did not commit the act or omission complained of, extinguishes civil liability arising from the crime. The Court of Appeals’ factual findings, which the Supreme Court affirmed, constituted a “complete exoneration” of Rosas. It was established that Rosas was driving prudently within his lane and could not have reasonably anticipated the sudden encroachment of Melvida’s car from the opposite direction. Since Rosas was found to be free from any negligence, no civil liability can be imposed upon him. Consequently, his employer, Victory Liner, Inc., cannot be held subsidiarily liable, as such liability presupposes a finding of criminal negligence by the employee. Regarding the Gali spouses, owners of the Plymouth car, they cannot be held subsidiarily liable under Article 103 of the Revised Penal Code. The law requires the employer to be engaged in “some kind of industry,” defined as a business or occupation employing labor and capital. Using a car for private purposes does not constitute an industry. Therefore, as private individuals not engaged in industry, they are not subsidiarily liable for the criminal act of their insolvent driver, Melvida.
