G.R. No. L-8238 - Carandang vs. Santiago

Cesar M. Carandang (petitioner) filed a civil case against Tomas Valenton, Sr. and Tomas Valenton, Jr. (respondents) before the Court of First Instance (CFI) of Manila, docketed as Civil Case No. 21173.
The civil case sought to recover actual and moral damages for bodily injuries allegedly inflicted by Tomas Valenton, Jr. on Cesar Carandang.
Prior to the civil case, Tomas Valenton, Jr. was criminally charged, tried, and found guilty of frustrated homicide against Cesar Carandang in Criminal Case No. 534, CFI of Batangas. Tomas Valenton, Jr. appealed the criminal conviction, and the appeal was pending before the Court of Appeals.

After defendants filed their answer, they moved to suspend the trial of the civil case pending the final resolution of the criminal appeal in the Court of Appeals.
Honorable Vicente Santiago, Judge of the CFI of Manila, granted the motion and suspended the trial to await the result of the criminal case.
Petitioner moved for reconsideration, which was denied by the court.
Consequently, Cesar Carandang filed a petition for certiorari seeking to annul the order suspending the civil case trial.

Petitioner cited Article 33 of the new Civil Code, which provides that in cases of defamation, fraud, and physical injuries, a civil action for damages may be brought independently of the criminal prosecution.
The provision states the civil action shall proceed independently and requires only a preponderance of evidence.
The petitioner argued that the civil suit for damages should proceed regardless of the status of the criminal case because Article 33 contemplates separate and independent proceedings.

Respondents contended that the term “physical injuries” in Article 33 refers to the specific crime of physical injuries under the Revised Penal Code.
Since Tomas Valenton, Jr. was convicted of the crime of frustrated homicide and not the crime of physical injuries, respondents argued that Article 33 did not apply to this civil action.
They claimed the word “physical injuries” should be interpreted in its technical and statutory meaning.

Whether or not the suspension of the trial of the civil case pending the termination of the related criminal case was proper and justified under Article 33 of the new Civil Code.
Whether the term “physical injuries” in Article 33 of the new Civil Code refers only to the specific crime of physical injuries under the Revised Penal Code or to any bodily injury regardless of the underlying crime charged.