Case Digest (G.R. No. 50959)
Facts:
Heirs of Pedro Tayag, Sr. filed a complaint for damages (Civil Case No. 5114) in the Court of First Instance of Tarlac, Branch I, alleging that on September 2, 1974, Pedro Tayag, Sr. was bumped by a Philippine Rabbit Bus driven by Romeo Villa y Cunanan, resulting in his instantaneous death and damage to his bicycle. The private respondents later moved to suspend the civil trial pending the criminal case, invoking Section 3, Rule 111; the trial court granted the motion and later acquitted Romeo Villa in Criminal Case No. 836 on the ground of reasonable doubt. After the acquittal, the private respondents moved to dismiss the civil case, arguing the driver’s acquittal barred the action; the trial court dismissed the complaint.Petitioners sought certiorari, claiming grave abuse of discretion and lack of jurisdiction.
Issues:
- Whether the trial court gravely abused its discretion and acted without or in excess of jurisdiction in dismissing Civil Case No. 5114 after the driver’s 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)