Case Digest (G.R. No. 75025) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Natividad v. Andamo and Emmanuel R. Andamo, petitioners Emmanuel and Natividad Andamo owned a parcel of land in Biga (Biluso), Silang, Cavite, adjacent to the property of private respondent Missionaries of Our Lady of La Salette, Inc. Between July 1982 and February 1983, petitioners instituted two actions in the Regional Trial Court of Cavite, Branch 4 (Tagaytay City). First, they filed a criminal complaint (Criminal Case No. TG-907-82) against officers and directors of the corporation for destruction by inundation under Article 324 of the Revised Penal Code. Thereafter, on February 22, 1983, they filed a civil complaint (Civil Case No. TG-748) for damages under Articles 2176 and 2177 of the Civil Code and prayed for a preliminary injunction, alleging that respondent had constructed waterpaths, culverts and an artificial lake on its land, causing recurrent flooding, erosion of their soil, destruction of fences, the drowning of a young man, and endangerment of lives and crops. Case Digest (G.R. No. 75025) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Property
- Petitioners Emmanuel and Natividad Andamo own a parcel of land in Biga (Biluso), Silang, Cavite.
- Respondent Missionaries of Our Lady of La Salette, Inc. is a religious corporation owning the adjacent parcel.
- Alleged Tortious Acts and Damages
- Within respondent’s land, waterpaths, culverts, an artificial lake and related contrivances were constructed, allegedly without due authority.
- These works purportedly caused year-after-year inundation and erosion of petitioners’ land, the drowning of a young man, destruction of crops and fences, and endangerment of lives during storms.
- Procedural History
- July 1982: Petitioners filed Criminal Case No. TG-907-82 under Article 324, Revised Penal Code, against corporate officers for destruction by inundation.
- February 22, 1983: Petitioners filed Civil Case No. TG-748 for damages and preliminary injunction under Articles 2176 and 2177, Civil Code.
- April – August 1984: Trial court first suspended, then dismissed the civil case under Section 3(a), Rule 111, Rules of Court, pending resolution of the criminal case.
- February 17, 1986: Intermediate Appellate Court affirmed dismissal; May 19, 1986: motion for reconsideration denied.
Issues:
- Whether a civil action for quasi-delict under Articles 2176 and 2177 of the Civil Code can proceed independently of a related criminal case under Section 3(a), Rule 111 of the Rules of Court.
- Whether the trial and appellate courts erred in dismissing the civil case for lack of jurisdiction due to the pending criminal case.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)