Title
Heirs of Tayag, Sr. vs. Alcantara
Case
G.R. No. 50959
Decision Date
Jul 23, 1980
Pedro Tayag, Sr. died in a bus accident; heirs sued for damages. Driver acquitted in criminal case, but civil case dismissed. SC ruled civil action based on quasi-delict independent, remanded for further proceedings.
A

Case Digest (G.R. No. 50959)

Facts:

  • Background of the dispute
    • Petitioners are the heirs of Pedro Tayag, Sr., namely Crisanta Salazar, Pedro Tayag, Jr., Renato Tayag, Gabriel Tayag, Corazon Tayag, and Rodolfo Tayag.
    • Petitioners filed with the Court of First Instance of Tarlac, Branch I a complaint for damages against Philippine Rabbit Bus Lines, Inc. and Romeo Villa y Cunanan, docketed as Civil Case No. 5114.
    • The complaint was filed on September 25, 1974.
    • Petitioners alleged that in the afternoon of September 2, 1974, while Pedro Tayag, Sr. was riding a bicycle along MacArthur Highway in Bo. San Rafael, Tarlac, Tarlac, he was bumped and hit by a Philippine Rabbit Bus.
    • Petitioners alleged that the bus involved had Body No. 1107 and Plate No. YL 604 PUB ’74.
    • Petitioners alleged that the driver was Romeo Villa.
    • Petitioners alleged that Pedro Tayag, Sr. sustained injuries that caused his instantaneous death.
    • Petitioners alleged that the bicycle he was riding on was damaged and destroyed.
  • Pleadings and motion to suspend the civil action
    • Private respondents filed their answer in due time, admitting some allegations and denying others.
    • Private respondents filed a motion to suspend the trial dated April 30, 1975, invoking that the criminal case against the driver was still pending in the same court.
    • Private respondents relied on Section 3, Rule 111 of the Revised Rules of Court, contending that it enjoined suspension of the civil action until termination of the criminal action.
    • The respondent judge granted the motion and suspended the hearing of Civil Case No. 5114.
  • Criminal case disposition and subsequent dismissal of the civil case
    • On October 25, 1977, the respondent judge rendered a decision in Criminal Case No. 836, acquitting Romeo Villa of the crime of homicide on the ground of reasonable doubt.
    • Thereafter, private respondents filed a motion to dismiss Civil Case No. 5114, arguing that petitioners had no cause of action because the driver had been acquitted.
    • Petitioners opposed the motion, asserting that their cause of action was not based on crime but on quasi delict.
    • On April 13, 1978, the respondent judge issued an order dismissing the complaint in Civil Case No. 5114.
    • Petitioners moved for reconsideration.
    • The respondent judge denied reconsideration in an order dated May 30, 1979.
  • Petition for certiorari and controlling question
    • Petitioners filed the present petition for certiorari to annul and set aside the dismissal order of the respondent judge.
    • Petitioners claimed that the respondent judge acted without or in excess of jurisdiction and/or with grave abuse of discretion, and that no plain, speedy, and adequate remedy existed except through the petition.
    • After submission of the private respondents’ comment, the Court deemed the case submitted for decision on September 3, 1979.
    • The only issue presented was whether the respondent judge acted without or in excess of jurisdiction and/or with grave abuse of discretion in dismissing Civil Case No. 5114. ...(Subscriber-Only)

Issues:

  • Whether the respondent judge committed grave abuse of discretion amounting to lack of jurisdiction in dismissing Civil Case No. 5114
    • Whether the civil action for damages based on quasi delict could proceed independently of the criminal proceeding despite the acquittal of the driver in Criminal Case No. 836.
    • Whether Section 3, Rule 111 of the Revised Rules of Court and its suspension requirement could defeat petitioners’ civil action where the complaint was based o...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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