G.R. No. L-78848 November 14, 1988
SHERMAN SHAFER, petitioner, vs. HON. JUDGE, REGIONAL TRIAL COURT OF OLONGAPO CITY, BRANCH 75, and MAKATI INSURANCE COMPANY, INC., respondents.

FACTS

Petitioner Sherman Shafer was charged with reckless imprudence resulting in damage to property and serious physical injuries. The information alleged that on May 17, 1985, he drove his Ford Laser car in a reckless manner, causing it to hit a Volkswagen. The accident resulted in property damage to the Volkswagen and serious physical injuries to passenger Jovencio Poblete, Sr. Shafer had a private car policy, including third-party liability (TPL) coverage, with respondent Makati Insurance Company, Inc. During the trial of the criminal case, where the civil action for damages arising from the injuries to Poblete was impliedly instituted, Shafer sought and was granted leave to file a third-party complaint against the insurer.
The trial court, however, dismissed the third-party complaint as premature. It ruled that unless Shafer is first found guilty and sentenced to pay indemnity, he has no cause of action against the insurer. The court believed the better procedure was to wait for the outcome of the criminal case. Shafer moved for reconsideration, arguing the dismissal curtailed his right to defend himself in the civil aspect. His motion was denied, prompting this petition.

ISSUE

Whether an accused in a criminal prosecution for reckless imprudence, where the civil action for damages is impliedly instituted, can implead his compulsory motor vehicle liability insurer as a third-party defendant.

RULING

Yes. The Supreme Court granted the petition and set aside the trial court’s order. The legal logic is anchored on the nature of compulsory motor vehicle liability insurance and the procedural purpose of a third-party complaint. Compulsory motor vehicle liability insurance is primarily intended to provide immediate financial compensation to injured third parties or passengers, irrespective of the insured’s financial capacity. Where an insurance policy insures directly against liability, the insurer’s liability accrues immediately upon the occurrence of the injurious event, not upon a final judgment against the insured. The injured party can even sue the insurer directly.
The Court emphasized that a third-party complaint is a procedural mechanism to bring into an existing suit a party against whom the defendant may claim indemnity. Its purpose is to avoid multiplicity of suits and promote expediency. In this case, the civil action for damages filed by the injured passenger is inseparable from the criminal action for reckless imprudence. Shafer’s claim for indemnity from his insurer arises directly from the same incident that gave rise to the criminal charge and the attached civil liability. Therefore, it is directly related to the case. Impleading the insurer does not introduce an extraneous matter; it allows for a complete resolution of all related claims in a single proceeding. To require Shafer to await a final judgment in the criminal case before suing the insurer would defeat the purpose of the third-party complaint rule and could lead to unnecessary and duplicative litigation.