Case Digest (G.R. No. 224597) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Special Civil Action No. 17-C (99) before the Municipal Circuit Trial Court of Capas, Tarlac (MCTC), respondent Mario Llavore Laroya and petitioners Avelino Casupanan (driver) and Roberto Capitulo (owner) sued one another following a vehicular accident. Laroya first filed Criminal Case No. 002-99 for reckless imprudence resulting in damage to property against Casupanan. While that criminal case was pending preliminary investigation, Casupanan and Capitulo instituted Civil Case No. 2089 for damages based on quasi-delict (Art. 2176, Civil Code) against Laroya. Laroya moved to dismiss the civil case for forum-shopping. On March 26, 1999, the MCTC granted the motion and dismissed the civil suit; the denial of reconsideration followed on May 7, 1999. Petitioners then filed a Rule 65 certiorari before the Regional Trial Court of Capas, Branch 66, which on December 28, 1999 dismissed the petition for lack of merit, holding that the MCTC’s order was final and appealable and that cert Case Digest (G.R. No. 224597) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- The Vehicular Accident and Initial Filings
- Two vehicles were involved in a collision: one driven by respondent Mario L. Laroya and the other owned by petitioner Roberto Capitulo and driven by petitioner Avelino Casupanan.
- As a result of the accident, Laroya filed Criminal Case No. 002-99 for reckless imprudence resulting in damage to property before the MCTC of Capas, Tarlac, while Casupanan and Capitulo instituted Civil Case No. 2089 for quasi-delict against Laroya in the same court.
- Proceedings in the MCTC and RTC
- Laroya moved to dismiss Civil Case No. 2089 on grounds of forum-shopping; the MCTC granted the motion (Order of March 26, 1999) and denied reconsideration (Order of May 7, 1999).
- Casupanan and Capitulo sought certiorari under Rule 65 before the RTC of Capas, Tarlac (Special Civil Action No. 17-C (99)). The RTC dismissed the petition (Resolution of December 28, 1999) and denied reconsideration (Resolution of August 24, 2000).
Issues:
- Primary Legal Question
- Whether an accused in a pending criminal case for reckless imprudence may validly prosecute, simultaneously and independently, a separate civil action for quasi-delict against the private complainant in the criminal case.
- Subsidiary Considerations
- Whether the MCTC’s dismissal of the civil complaint for forum-shopping was a final, appealable order or a non-appealable dismissal without prejudice.
- Whether certiorari under Rule 65 was the proper remedy for Casupanan and Capitulo.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)