G.R. No. 116600 - People vs. Manlusoc

Petitioners: Francisco Bonite, Candido Bonite, Venecia Bonite, Constancio Bonite, Ernesto Bonite, Angelina Bonite, Maria Bonite, and Juanita Bonite (for herself and her minor children, Nadija, Nerio, Felix, and Maria Fedila Bonite).
Respondents: Hon. Mariano A. Zosa, Presiding Judge, Court of First Instance of Misamis Occidental, 16th Judicial District, Branch III; Eligio Abamonga.

On 24 September 1968, at about 2:00 P.M., Florencio Bonite, employed as a "caminero" of the Bureau of Public Highways in Barrio Vicente Alto (Dagatan), Oroquieta City, was struck by a truck.
The truck was driven by private respondent Eligio Abamonga, resulting in the death of Florencio Bonite on the same day.

Following Bonite’s death, the surviving heirs (the petitioners) filed a criminal complaint for Homicide through Reckless Imprudence.
The case was docketed as Criminal Case No. 9328 with the City Court of Oroquieta City.
Petitioners, represented by their counsel Atty. Alberto Dulalas acting as private prosecutor, actively participated in the criminal proceedings.
The criminal case ended in an acquittal of Abamonga for failure of the prosecution to prove his guilt beyond reasonable doubt.

On 28 December 1970, petitioners filed an action for recovery of damages (Civil Case No. 2806) against Abamonga for the death of Florencio Bonite.
The Court of First Instance of Misamis Occidental, 16th Judicial District, Branch III issued an order on 25 February 1971 dismissing the complaint.
The court’s reasoning was that petitioners did not reserve the right to file an independent civil action during the criminal case and that their active participation in that prosecution rendered the civil action res judicata.
A subsequent motion for reconsideration by the petitioners was denied on 27 March 1971.

Whether an independent civil action for damages under Article 29 of the Civil Code is barred by:

Petitioners’ failure to reserve the right to bring such action during the criminal prosecution.
Their active participation in prosecuting the criminal case.

Does the absence of a reservation in the criminal action preclude the petitioners from subsequently instituting a separate civil action for damages?

Whether the active role of the petitioners in the criminal prosecution, as private prosecutors, bars their right to file an independent civil action for damages after the accused’s acquittal.

Whether Article 29 of the Civil Code, which allows filing a civil action for damages following an acquittal based on reasonable doubt, applies even if the accused is acquitted in a criminal case.
The relevance of Article 2176 of the Civil Code, which covers quasi-delict and negligence.
The appropriateness of applying Article 33 of the Civil Code in cases involving criminal negligence, specifically in situations of reckless imprudence leading to homicide.

Whether the enforcement of Article 29 should be subject to the procedure of a reservation requirement under Section 2 of Rule 111 of the former Rules on Criminal Procedure.