Heirs of Teodoro Guaring, Jr. vs Court of Appeals

written by Howard

G.R. No. 108395 – 336 Phil. 274 – 269 SCRA 283 – Civil Law – Torts and Damages – Quasi-Delict

Sometime in November 1987, Teodoro Guaring, Jr., driving a Mitsubishi Lancer headed north along the North Expressway in Pampanga when he was hit by a Philippine Rabbit Bus driven by Angeles Cuevas. The Lancer was thrown to the opposite lane. Guaring died as a result of the incident. Thereafter, the heirs of Guaring filed a criminal case against Cuevas for reckless imprudence resulting in homicide. The heirs also filed a separate civil case for damages against the Philippine Rabbit Bus Lines, Inc. and Cuevas.

The criminal case was dismissed on reasonable doubt. The heirs won the civil case and the bus company and Cuevas were directed to pay to the heirs. Philippine Rabbit appealed. On appeal, the Court of Appeals reversed the decision of the RTC on the ground that since the basis of the damages case was the criminal case which was dismissed, the acquittal rendered the civil case based on quasi delict untenable.

ISSUE: Whether or not the judgment in the criminal case extinguished the liability of Philippine Rabbit Bus Lines and its driver for damages for the death of Guaring.

HELD: No. The case is remanded to the Court of Appeals. The reversal by the CA of the RTC decisions was improper. Based on record, the CA did not even have before it the evidence in the criminal case. What it did was simply cite the findings contained in the decision of the criminal court. This case must be decided on the basis of the evidence in the civil case.

Article 2176 states Who ever by act or omission causes damage to another, there being fault or negligence, is obliged to pay for the damage done. Such fault or negligence, if there is no pre-existing contractual relation between the parties, is called a quasi-delict and is governed by the provisions of this Chapter.

The acquittal of the accused, even if based on a finding that he is not guilty, does not carry with it the extinction of the civil liability based on a quasi-delict. A separate civil action lies against the offender in a criminal act, whether or not he is criminally prosecuted and found guilty or acquitted, provided that the offended party is not allowed, if he is actually charged also criminally, to recover damages on both scores, and would be entitled in such eventuality only to the bigger award of the two, assuming the awards made in the two cases vary.

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