Facts:

In the case of Natividad v. Andamo and Emmanuel R. Andamo, decided on November 6, 1990, the petitioners, spouses Emmanuel and Natividad Andamo, owned a parcel of land in Biga (Biluso), Silang, Cavite. Their land was adjacent to that of the respondent, Missionaries of Our Lady of La Salette, Inc., a religious corporation. The respondent corporation constructed waterpaths, water conductors, and an artificial lake within its property that allegedly caused inundation and erosion damage to the petitioners’ land. This flooding resulted in the erosion of land, destruction of crops and fences, and even led to the drowning of a young man, endangering the lives of the petitioners and their laborers during rainy and stormy seasons. Initially, in July 1982, the petitioners filed a criminal case (Criminal Case No. TG-907-82) against officers and directors of the respondent corporation for destruction by inundation under Article 324 of the Revised Penal Code. Subsequently, in February 1983, t

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Facts:

Parties and Property

• Petitioners: Emmanuel and Natividad Andamo, owners of a parcel of land in Biga (Biluso), Silang, Cavite.
• Respondent: Missionaries of Our Lady of La Salette, Inc., a religious corporation owning adjacent property.

Construction and Development on Respondent’s Land

• Construction of waterpaths, water conductors, contrivances, and an artificial lake within the respondent’s land.
• Detailed features of the construction:
• Waterpaths built through the land starting from the middle-right portion.
• Construction of openings in the concrete hollow-block fence facilitating the system.
• Use of interconnected cement culverts and galvanized iron pipes to channel water.

Alleged Damages and Injuries

• Inundation and erosion of petitioners’ adjacent land.
• Specific damages claimed by petitioners:
• Flooding led to a young man drowning.
• Erosion causing loss of arable land.
• Repeated washing away of costly fences.
• Endangerment of the lives of petitioners and their laborers during rainy and stormy seasons.
• Destruction or exposure of crops, plants, and other improvements on the land.

Initiation of Legal Actions

• Criminal Action
• Filed in July 1982 under Criminal Case No. TG-907-82 before the Regional Trial Court of Cavite, Branch 4 (Tagaytay City).
• Charges against officers and directors of the respondent corporation for destruction by means of inundation under Article 324 of the Revised Penal Code.
• Civil Action
• Filed on February 22, 1983 under Civil Case No. TG-748 seeking damages and a writ of preliminary injunction.
• The civil case was based on alleged violations of Articles 2176 and 2177 of the Civil Code on quasi-delicts.

Procedural Developments and Court Orders

• Respondent filed an answer and opposition to the preliminary injunction on March 11, 1983.
• The trial court, acting on a motion by the respondent, suspended further hearings in the civil case pending the outcome of the criminal case.
• On August 27, 1984, the trial court dismissed the civil case due to lack of jurisdiction, referring to Section 3(a), Rule III of the Rules of Court.
• The dismissal was upheld by the Intermediate Appellate Court on February 17, 1986, and a motion for reconsideration by petitioners was denied on May 19, 1986.

Issue:

Jurisdiction and Independence of the Civil Action

• Whether a civil action for damages based on quasi-delict (culpa aquiliana) can proceed independently from a pending criminal case arising from the same set of facts.
• Whether the trial court erred in dismissing Civil Case No. TG-748 on the basis that a criminal proceeding had already been instituted.

Nature and Characterization of the Cause of Action

• Whether the allegations in the petitioners’ complaint, which detail the construction of waterpaths and the resulting damages, sufficiently constitute a claim under Articles 2176 and 2177.
• The determination of an action’s nature by the factual allegations in the complaint rather than by the title or the remedial law invoked.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)