G.R. No. 1312 - People vs. Bundal

Petitioner: Merlin P. Caina, accused of reckless imprudence resulting in serious physical injuries.
Respondents:

The Municipal Trial Court acquitted Merlin P. Caina of the criminal charge on the ground that the prosecution failed to establish his guilt beyond a reasonable doubt.
Despite the acquittal, the trial court still awarded the private complainant, Dolores Perez, the sum of P2,893.40 as actual damages based on the evidence presented.
The dispositive portion of the trial court’s decision stated that while the accused was acquitted criminally, he was still liable to compensate for the damages incurred.

The petitioner appealed the award of damages to the Regional Trial Court (RTC), contesting the civil liability imposed upon him.
The RTC initially reversed the trial court decision regarding the damage award, thereby absolving him of civil liability.
Upon a Motion for Reconsideration by the private complainant, the RTC reversed its own decision and reinstated the original award of damages.

The petitioner, in his appeal, raised the issue that the award of damages was void and illegal due to the absence of a preponderance of evidence establishing a causal connection between his actions and the damage suffered.
The petitioner’s notice of appeal was erroneously filed with the RTC as a Supreme Court appeal on a pure question of law instead of filing a petition for review on certiorari as required.
The RTC and subsequently the Court of Appeals forwarded the case to the Supreme Court despite the noted procedural error.

A key piece of evidence was the testimony of prosecution witness Rene Abas, stating that the speed of the accused’s jeep was within normal limits, implying no recklessness, negligence, or imprudence.
The trial court’s record clearly indicated that no sufficient evidence was presented to prove the requisite elements (recklessness, negligence, and imprudence) for a crime that could form the basis of civil liability.

The acquittal on the criminal charge and the evidence presented collectively suggest that the act from which civil liability might arise did not occur.
The award of damages, therefore, lacked a factual basis since it rested on a non-existent or unproven wrongful act.

Whether the trial court and the Regional Trial Court erred in awarding civil damages against the petitioner in the absence of any finding establishing a causal link between the alleged wrongful act and the actual damages suffered by the complainant.
Whether the act that could give rise to civil liability was even present in the case, considering the acquittal on criminal grounds.

Whether the petitioner’s appeal, which was filed via notice of appeal rather than through a petition for review on certiorari (as mandated by the Rules of Court), should have been dismissed for failing to conform to the proper appellate procedure.
The distinction between pure questions of law (which would warrant a petition for certiorari) and questions of fact (which involve the evaluation of evidence and credibility).