G.R. No. 230628 - Small Business Corp. vs. Commission on Audit

On November 23, 1992, at around 11:50 in the morning at Brgy. Dolores, Capas, Tarlac, the accused, while driving a Philippine Rabbit Bus (Plate No. CVE-707), collided with a Toyota jeep (Plate No. TAB 929).
The collision, caused by the careless, negligent, and imprudent handling of the vehicle without due regard for applicable laws and traffic regulations, resulted in the death of Eduardo Mangawang who was driving the jeep.
The incident also resulted in damages to the jeep, the extent of which was left undetermined in the Information.
The charge filed was for reckless imprudence resulting in homicide, rooted in the accused’s management of the bus.

An Information was filed on July 23, 1993, before the RTC of Capas, Tarlac, Branch 66.
The trial court rendered judgment on November 12, 1999, convicting Ernesto Ancheta beyond reasonable doubt of the crime.
The conviction imposed an indeterminate penalty ranging from two (2) years and four (4) months to six (6) years of prision correccional.
In addition to the criminal penalties, the RTC ordered the accused to pay civil liabilities to the heirs of the deceased, including:

Compensatory damages: P28,600.00.
Loss of earning capacity: P1,436,466.30.
Indemnification for the death of Eduardo Mangawang: P50,000.00 and an additional P50,000.00 as moral damages.

The accused appealed to the Court of Appeals (CA), but his appeal was dismissed on November 10, 2000, for failure to file a timely brief; the RTC decision became final and executory on December 7, 2000.
Subsequently, on June 29, 2001, PRBLI as the employer filed a Notice of Appeal concerning the RTC decision, asserting its civil liability.
The RTC initially denied the notice of appeal on July 18, 2001, on the basis that it was filed after the judgment had become final and executory.
PRBLI pursued further motions for reconsideration and clarification, which were denied until the trial court, on October 17, 2001, eventually granted the motion, thus transmitting the records to the CA for appellate consideration.
On October 10, 2003, the CA rendered judgment affirming the RTC decision with one material modification: the actual damages award was reduced to P5,000.00, while the rest of the decision remained unaltered.
The CA also dismissed PRBLI’s appeal on the ground that, as the employer (a non-party to the criminal proceedings), it was bound by the RTC decision concerning both the criminal conviction and the imposed subsidiary civil liability.

PRBLI filed the present petition for review before the Supreme Court, challenging the CA decision.
The petitioner contended that:

The conviction of the accused had not attained finality as it affected its civil liability.
It was deprived of its right to due process because it was not furnished copies of the RTC decision, the CA’s resolution, and subsequent orders.
It should have the standing and opportunity to question the measure of civil liability imposed, citing precedents (e.g., Pajarito v. Seneris and Miranda v. Malate Garage & Taxicab, Inc.) which allegedly supported a reconsideration of such determinations.

The RTC decision, following the dismissal of the accused’s appeal, was final and executory.
The petitioner, not being a direct party in the criminal case, had no entitlement to copies of the decisions or the right to appeal the civil liability award.

Whether the employer, PRBLI, as a non-party to the criminal proceedings but affected by subsidiary civil liability, has the right and standing to appeal the RTC decision for purposes of contesting both the existence and quantum of its imposed liability.

Whether the alleged denial of due process, based on PRBLI’s claim that it was not provided with copies of the RTC decision, the CA resolution, and related orders, is valid.

Whether the Court of Appeals properly modified the RTC decision regarding the award of actual damages, despite the decision having long become final and executory.

Whether allowing an employer’s appeal in such criminal proceedings would violate the principles of double jeopardy and the finality of judicial decisions.