Facts:

On November 25, 1969, Felix Lanuzo (plaintiff-appellee) initiated a civil complaint for damages (Civil Case No. 6847) against Sy Bon Ping and Salvador Mendoza (defendants-appellants) in the Court of First Instance of Camarines Sur. The plaintiff alleged that on July 24, 1969, at around 5:00 PM, while Salvador Mendoza was operating a freight truck owned by Sy Bon Ping along the national highway in San Ramon, Nabua, Camarines Sur, he recklessly drove the vehicle into Lanuzo's residential house and store, resulting in complete destruction. This incident caused damages amounting to P13,000.00, which included loss of livelihood since the plaintiff’s store generated a monthly income of P300.00. The defendants responded to the complaint by filing a motion to dismiss, arguing that a related criminal case (Criminal Case No. 4250) for damages due to reckless imprudence was ongoing in the Municipal Court of Nabua, asserting that the civil action should not proceed until the criminal ca

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Facts:

The Incident and Initiation of Action

• On July 24, 1969, at about five o’clock in the afternoon, the freight truck bearing Plate No. T-57266, driven by Salvador Mendoza, was involved in an accident along the national highway in the Barrio of San Ramon, Nabua, Camarines Sur.
• Due to the alleged reckless negligence of the driver, the truck rammed into the residential house and store of plaintiff Felix Lanuzo, completely razing them and causing substantial damage.

Plaintiff’s Claims and Reservation

• Plaintiff Felix Lanuzo instituted a Complaint for damages (Civil Case No. 6847) in the Court of First Instance of Camarines Sur alleging damages amounting to P13,000.00.
• In his complaint, the plaintiff charged that due to the loss of his house, store, and consequently his means of livelihood (monthly income of P300.00), he suffered irreparable harm.
• Importantly, the plaintiff reserved his right to institute a separate civil action for damages within a concurrently pending criminal case (Criminal Case No. 4250) by expressly stating his intention to pursue a civil claim based on quasi-delict.

Procedural Background and Lower Court Decisions

• In August 1970, the trial court rendered a default judgment in favor of the plaintiff, ordering:
• The defendants to pay jointly and severally the damages amounting to P13,000.00.
• A monthly indemnity of P300.00 from the date of the incident until the full payment is made.
• Attorney’s fees at 20% of the total claim, in addition to the costs of the suit.
• Defendants’ subsequent Motion for Reconsideration and/or New Trial was denied by the trial court.
• On appeal, the defendants argued that the civil action was prematurely instituted due to Rule 111, Section 3, which mandates the suspension of a civil action (arising from delict) pending the result of a related criminal proceeding.

Nature of the Civil Claim and Legal Distinction Made

• The plaintiff’s reservation in the criminal case clearly indicated that his civil claim was based on quasi-delict (culpa aquiliana) and not the criminal liability arising from the same wrongful act.
• This reservation delineated two distinct remedies: one based on the criminal prosecution under Article 100 of the Revised Penal Code and another based on a civil action for quasi-delict under Articles 1902-1910 of the Civil Code.
• The courts recognized that these two remedies could independently coexist because the criminal proceeding did not exhaust or preclude the civil claim for damages.

Issue of Defendant’s Liability and the Separation of Liabilities

• It was alleged that the negligence of driver Salvador Mendoza was the proximate cause of the property damage.
• The employer, Sy Bon Ping, was implicated through the employer-employee relationship and was held directly liable under Article 2180 of the Civil Code, which imposes liability on employers for the acts of their employees when such acts are committed within the scope of their employment.
• The trial court’s judgment imposed joint and several liability on both the driver and the employer.

Issue:

Whether the filing of a civil action for damages based on quasi-delict is permissible despite the concurrent criminal case for the same act.

• Does Rule 111, Section 3, which suspends civil action arising from delict pending a criminal suit, apply to a claim for quasi-delict?

The nature and extent of the defendants’ liability.

• Whether the driver’s action constitutes a negligence sufficient to invoke primary liability under Article 2176 of the Civil Code.
• Whether the employer’s liability as provided under Article 2180 is primary and solidary due to his failure in the selection and supervision of his employee.

The validity of the plaintiff’s express reservation.

• Whether the reservation made in the criminal case expressly preserved the plaintiff’s right to file a separate civil suit for quasi-delict damages.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)