G.R. No. 80194 - Jarantilla vs. Court of Appeals

On the evening of July 7, 1971, private respondent Jose Kuan Sing was sideswiped by a Volkswagen (Beetle type) vehicle in Iznart Street, Iloilo City.
The vehicle was driven by petitioner Edgar Jarantilla, who was moving toward the provincial capitol.
Respondent sustained physical injuries from the accident.
Petitioner was charged with serious physical injuries through reckless imprudence before the City Court of Iloilo, Case No. 47207, with private respondent as the complaining witness who intervened through a private prosecutor but did not reserve his right to a separate civil action.
Petitioner was acquitted based on reasonable doubt, and no civil liability was adjudicated in the criminal ruling.

On October 30, 1974, respondent filed a separate civil complaint against petitioner in the Court of First Instance of Iloilo (Civil Case No. 9976), involving the same subject matter and act as the criminal case.
Petitioner asserted defenses including lack of cause of action and that the civil action was barred by prior judgment due to private respondent's failure to reserve civil rights and his intervention in the criminal prosecution.
A motion to dismiss was denied by the trial court in April 1975, which suggested petitioner bring the matter to the Supreme Court for review.
Petitioner filed a special civil action (certiorari, prohibition, and mandamus) before the Supreme Court, docketed as G.R. No. L-40992, but the petition was dismissed for lack of merit.

After trial, the Court of First Instance rendered judgment on May 23, 1977, in favor of private respondent, awarding P6,920.00 for hospitalization and medicines, P2,000.00 for other expenses, P25,000.00 for moral damages, P5,000.00 for attorney’s fees, and costs.
On July 29, 1987, the Court of Appeals affirmed the lower court decision, except that it reduced moral damages from P25,000.00 to P18,000.00.
A motion for reconsideration filed by petitioner was denied by the Court of Appeals on September 18, 1987.

Whether private respondent, who had intervened in the criminal prosecution without reserving civil rights, could thereafter maintain a separate civil action for damages where petitioner had been acquitted on reasonable doubt and no civil liability was included in the criminal judgment.

Can a private complainant who participated in a criminal case without reserving civil action rights, and where the accused was acquitted on reasonable doubt with no civil liability resolved, subsequently file a separate civil action arising from the same act?
Does the doctrine of "law of the case" apply to bar petitioner’s claims in the subsequent civil action based on prior dismissals related to interlocutory matters in the criminal/civil proceeding?
What is the effect of non-inclusion of civil liability in the judgment of acquittal regarding the right to file a civil action for damages?