G.R. No. 199687 - Pacific Rehouse Corp. vs. Court of Appeals

On July 25, 1951, a truck owned by Zacarias Sarabia and driven by Emilio Celeste collided with a truck operating under the Mary Lim Line.
As a result of the collision, the truck driven by Sarabia plunged into a creek.
Gaudencio Basco, one of the passengers in Sarabia’s truck, died from injuries sustained during the accident.

On April 19, 1955, the widow and heirs of the deceased Gaudencio Basco filed a complaint against Zacarias Sarabia and Emilio Celeste for compensation and damages, alleging breach of a contract of carriage.
Subsequently, on July 11, 1955, the defendants (Sarabia and Celeste) filed a third-party complaint against Juan Cadungon, driver of the Mary Lim truck, and originally against Quintin Lim as owner and operator of that truck.
The third-party complaint was later amended on December 20, 1955 to nominate Maria M. Lim as the owner and operator of the truck.
On January 24, 1956, Maria M. Lim moved to dismiss the third-party complaint on two grounds:

The trial court sustained her motion on the ground of prescription and dismissed the complaint against her, prompting an appeal from the appellants.

Appellants: Plaintiffs Zacarias Sarabia and third-party plaintiffs sought to implicate Maria M. Lim in the incident, contending that her truck, operated under Mary Lim Line No. 108 and driven by Juan Cadungon, was directly responsible for the collision.
Appellee: Maria M. Lim argued that no cause of action existed against her and that, even if there were grounds for a claim, the action was time-barred by prescription under the Civil Code.

The underlying claim was essentially a quasi-delict action for damages arising from a wrongful act (negligent, reckless, and imprudent driving).
The case involved complex issues of third-party liability and the application of prescription periods in actions based on quasi-delicts, particularly regarding when the period should begin to run.

Whether the action against Maria M. Lim, based on a quasi-delict, prescribed under Article 1146 of the New Civil Code because it was instituted more than four years after the accident.
Whether the four-year prescription period should be computed from the date of the collision (July 25, 1951) or from the filing of the original complaint (April 19, 1955) or even from the filing of the amended third-party complaint (December 20, 1955).

Whether the privilege afforded by Rule 12, Section 1 (allowing a defendant to bring in a third party to seek contribution, indemnity, or subrogation) could be invoked in a situation where the primary action had already been barred by prescription.
Whether the initiating of criminal proceedings (regarding the negligent act) might have any effect on or interrupt the running of the four-year prescription period.

Whether, under the principle of solidary liability, appellants could still invoke the defense of prescription from the liability of Maria M. Lim, even if she were not joined as a party defendant.