Case Digest (G.R. No. L-18116)
Facts:
Clodualdo Meneses, Eupemio Trinidad, Jose Calara, Narciso Sigua and Nicolas Lorenzo v. Estanislao Luat and Abelardo G. Tinio, G.R. No. L-18116, November 28, 1964, Supreme Court En Banc, Makalintal, J., writing for the Court.Plaintiffs-appellants (the injured carretela owner and his passengers) sued defendants-appellees Estanislao Luat (the truck driver) and Abelardo G. Tinio (the truck owner) in Civil Case No. 1853 of the Court of First Instance of Pampanga for damages arising from an accident on February 14, 1960, in Apalit, Pampanga, in which a cargo truck with trailer driven by Luat struck a horse-drawn rig owned and driven by plaintiff Nicolas Lorenzo, killing the horse, wrecking the rig and injuring the plaintiffs.
Prior to the civil action a criminal complaint for damage to property with serious physical injuries was filed against Estanislao Luat in the same Court of First Instance. The plaintiffs there appeared by counsel as private prosecutors. On arraignment the accused pleaded guilty and was sentenced; the criminal court made no pronouncement on civil damages, no claim for damages was presented in that criminal proceeding, and no express reservation of a separate civil action was entered in the record. The criminal judgment became final and the accused began serving his sentence.
The plaintiffs thereafter filed the separate civil action on the theory of quasi-delict and invoking Article 33 of the Civil Code, which permits an independent civil action for defamation, fraud and physical injuries. Defendants filed a motion to dismiss the civil complaint on the ground that the action was barred by the criminal judgment. The Court of First Instance granted the motion and dismissed the complaint. The trial court relied on this Court’s decision in Maria C. Roa v. Segundina de la Cruz (107 Phil. 8, Feb. 13, 1960), which had held that an offended party who intervened actively as private prosecutor without reserving the right to sue civilly is barred from instituting a separate civil action.
Plaintiffs appealed the dismissal to the Supreme Court (regular appeal from the trial court order). The Supreme Cour...(Pro-only)
Issues:
- Does the rule in Maria C. Roa v. Segundina de la Cruz — that active intervention as private prosecutor without reserving the right to institute a separate civil action bars a later civil suit — apply where the criminal case did not proceed to trial because the accused pleaded guilty on arraignment?
- Is the civil action for damages barred by the prior criminal judgment ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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