Case Digest (G.R. No. 108395)
Facts:
Heirs of the Late Teodoro Guaring, Jr. v. Court of Appeals, G.R. No. 108395, March 07, 1997, Supreme Court Second Division, Mendoza, J., writing for the Court.Petitioners are the heirs of the late Teodoro Guaring, Jr.; private respondents are Philippine Rabbit Bus Lines, Inc. (PRBL) and its driver Angeles Cuevas; the Court of Appeals is the respondent in its capacity as the appellate tribunal that reviewed the civil judgment. The case arose from a vehicular collision on November 7, 1987, along the North Expressway in San Rafael, Mexico, Pampanga involving (1) a Mitsubishi Lancer driven by Teodoro Guaring, Jr., (2) Philippine Rabbit Bus No. 415 driven by Angeles Cuevas, and (3) a Toyota Cressida driven by Eligio Enriquez. Guaring died from the accident; Dolores Enriquez (in the Cressida) also died, and several passengers were injured.
Petitioners sued PRBL and Cuevas in the Regional Trial Court (RTC) of Manila, Branch 20, for damages based on quasi-delict (Art. 2176, Civil Code). Petitioners’ evidence tended to show the Rabbit bus attempted to overtake Guaring’s Lancer on the right shoulder and struck its right rear, causing the Lancer to swerve into the oncoming Cressida. Private respondents, by contrast, presented evidence asserting that Guaring attempted to overtake another vehicle, encroached on the south-bound lane and collided first with the Cressida, that the Lancer was thereafter thrown back into its lane and struck the bus.
On May 16, 1990, the RTC rendered judgment finding PRBL and Cuevas jointly and severally liable and awarded P500,000 for loss of earning capacity, P1,000,000 as moral damages, P50,000 attorneys’ fees, and costs of suit. PRBL appealed to the Court of Appeals, assigning several errors including that the proximate cause was Guaring’s negligence, that PRBL exercised due diligence, and that the damage awards were excessive.
On December 16, 1992, the Court of Appeals set aside the RTC civil judgment and dismissed the complaint, relying on a separate criminal trial in the RTC at San Fernando, Pampanga, which had acquitted Cuevas of reckless imprudence resulting in double homicide and damage to property. The CA treated the criminal acquittal as establishing that the bus driver was not negligent and therefore extinguishing the civil liability.
Petitioners then filed the present petition for review with the Supreme Court seeking reversal of the Court of Appeals’ decision. Their principal contentions were that (1) evidence or findings in a criminal case cannot be made conclusive against a civil plaintiff not a party to that criminal prosecution; (2) the Court of Appeals failed to resolve the factual issues and rendered a void judgment; and (3...(Subscriber-Only)
Issues:
- Does the criminal acquittal of the bus driver extinguish the civil liability of the driver and carrier in a civil action for damages founded on quasi-delict?
- Did the Court of Appeals err in setting aside the RTC civil judgment without reviewing the evidence in the civil case and instead relying on findings in th...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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