Facts:
The petitioner is
George Manantan and the private respondents are
Spouses Marcelino Nicolas and Maria Nicolas; the incident occurred on September 25, 1982 along the Maharlika Highway at Barangay Malvar, Santiago, Province of Isabela. On June 1, 1983 the Provincial Fiscal of Isabela filed an information charging Manantan with reckless imprudence resulting in homicide, alleging that while driving an automobile he sideswiped a passenger jeepney driven by Charles Codamon, causing the death of Ruben Nicolas, a passenger. The evidentiary record recounted a day of drinking and social outings during which the parties rode in the accused’s vehicle, and narratively described a collision that caused the car to overturn, left several occupants injured, and resulted in the death of Ruben Nicolas at the Flores Clinic the same night. At trial the defense maintained that the jeepney suddenly swerved into their lane and that the accused was driving slowly; the prosecution emphasized intoxication and negligent driving. The Regional Trial Court, Branch 21, Santiago, Isabela, rendered a decision dated June 30, 1988 (promulgated August 4, 1988) acquitting Manantan of the criminal charge without ruling on civil liability. The Nicolas spouses appealed the civil aspect on August 8, 1988. The Court of Appeals, in CA-G.R. CV No. 19240, rendered a decision dated January 31, 1992 modifying the trial court’s judgment by holding Manantan civilly liable and ordering indemnity and damages totaling P174,400.00 (P104,400.00 loss of support, P50,000.00 death indemnity, P20,000.00 moral damages), on the ground that Manantan was intoxicated and in violation of
Sec. 53, R.A. No. 4136, which, together with
Art. 2185, Civil Code, gave rise to a statutory presumption of negligence; the Court of Appeals denied reconsideration on August 24, 1992. Manantan petitioned this Court challenging the civil award and the appellate court’s jurisdiction.
Issues:
Did the trial court’s criminal acquittal of
George Manantan preclude the Court of Appeals from inquiring into his negligence or reckless imprudence in adjudicating civil liability?; Did the trial court’s acquittal extinguish petitioner’s civil liability for the death of
Ruben Nicolas?; Did the Court of Appeals lack jurisdiction to award damages because the private respondents did not pay filing fees for their implied civil action in violation of the
Manchester Development Corporation v. Court of Appeals doctrine and related Supreme Court directives?
Ruling:
Ratio:
Doctrine: