Case Digest (G.R. No. 156132)
Facts:
The case at hand involves Linday Paleyan, representing herself and her minor children—Teresa, Fortunato, Venancio, and Jose, all surnamed Paleyan, as plaintiffs-appellants against defendants-appellees Carlos Bangkili and Victoria Bangkili, alias Cuyoyan. The case arose from a tragic incident that occurred on November 21, 1960, when Carlos Bangkili, who was a minor at the age of 19 and living with his mother Victoria Bangkili, committed homicide resulting in the death of Balos Paleyan. Following this incident, Carlos was charged with homicide and wounding another victim and subsequently pleaded guilty, which led to a conviction without specific mention of civil indemnity for the heirs of the deceased. On April 3, 1961, Linday Paleyan and her children filed a civil action for damages against Carlos and his mother, Victoria. The trial court ultimately ruled in favor of the plaintiffs against Carlos, ordering him to pay indemnity, moral damages, and other related expenses totaling
Case Digest (G.R. No. 156132)
Facts:
- Background of the Case
- Plaintiffs consist of Linday Paleyan for herself and on behalf of her minor children Teresa, Fortunato, Venancio, and Jose Paleyan.
- Defendants are Carlos Bangkili and his mother, Victoria Bangkili (alias Cuyoyan).
- Criminal Incident and Conviction
- Balos Paleyan, the husband of the plaintiff and father of the children, was killed, and another victim was wounded.
- Carlos Bangkili, only 19 years old at the time and residing with his mother, was accused and later pleaded guilty in Criminal Case No. 898 before the Court of First Instance of Mountain Province for homicide with less serious physical injuries.
- Although a plea of guilty was entered on November 21, 1960, the criminal decision rendered no pronouncement as to the civil indemnity owed to the heirs of the deceased.
- Filing of the Civil Case and Trial Court Decision
- On April 3, 1961, the plaintiffs filed an action for damages against both Carlos Bangkili and Victoria Bangkili.
- The trial court rendered judgment awarding:
- P6,000.00 as indemnity for the death of Balos Paleyan.
- P1,000.00 as moral damages.
- P500.00 for expenses incurred.
- P500.00 as attorney’s fees.
- Payment of court costs.
- The complaint against Victoria Bangkili was dismissed on the ground that:
- Under Article 101 of the Revised Penal Code, she could not be held civilly liable for the criminal act committed by her minor son (despite him being 19 years old).
- Article 2180 of the New Civil Code was considered applicable only to obligations arising from quasi-delicts, and not to those arising from crimes.
- Post-Trial Developments and Legal Motions
- Plaintiffs moved for a reconsideration of the dismissal of the complaint against Victoria Bangkili; this motion was denied.
- The plaintiffs then instituted an appeal regarding the dismissal against the defendant Victoria Bangkili, while the judgment against Carlos Bangkili (with his liability finalized) was left unchallenged by the parties.
Issues:
- Primary Issue
- Whether the trial court was correct in dismissing the claim against defendant Victoria Bangkili given that:
- She was the natural guardian and had custody of her minor son at the time he committed the wrongful act.
- The statutory provisions under Article 101 of the Revised Penal Code and Article 2180 of the New Civil Code were interpreted by the lower court in a way that excluded her liability.
- Subsidiary Considerations
- The applicability of Article 2180 of the Civil Code to cases where the wrongful act was committed with criminal intent rather than stemming from a quasi-delict.
- How prior decisions (such as Exconde vs. Capuno; Araneta vs. Arreglado; Fuellas vs. Cadano; and Salen et al. vs. Balce) influence the liability of a parent even when the child is sufficiently mature (i.e., 19 years old) to be considered capable of discernment.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)