A.M. No. 07-8-3-SC - Re: 10% Salary Increase under Executive Order No. 611

PHILIPPINE RABBIT BUS LINES, INC. as petitioner and employer of the accused.
Ernesto Ancheta as accused and driver of a Philippine Rabbit passenger bus.
HEIRS OF EDUARDO MANGAWANG and PEOPLE OF THE PHILIPPINES as respondents and private prosecutor.

On November 23, 1992 at around 11:50 a.m., at Brgy. Dolores, Municipality of Capas, Tarlac, the bus driven by Ancheta, bearing Plate No. CVE-707 and MVRR No. 63044987, cruising MacArthur Highway south, bumped the left rear side of a Toyota jeep, Plate No. TAB 929 and MVRR No. 64284647, driven north by Eduardo Mangawang.
As a result of the collision, Eduardo Mangawang died and the jeep sustained damage.
An Information was filed on July 23, 1993 in RTC Capas, Branch 66, charging Ancheta with reckless imprudence resulting in homicide. The Information alleged negligence, imprudence, violation of Land Transportation laws, and civil prejudice to the deceased and the owner.

The accused was defended by Atty. Crispiniano Lamorena, Jr., assigned by PHILIPPINE RABBIT BUS LINES, INC.; Atty. Andres Pangilinan entered as private prosecutor.
The Regional Trial Court (Judge Josefina D. Ceballos) rendered judgment on November 12, 1999, finding Ernesto Ancheta guilty beyond reasonable doubt of Reckless Imprudence Resulting to Homicide.
Criminal penalty imposed: indeterminate imprisonment of two (2) years and four (4) months of prision correccional (minimum) to six (6) years of prision correccional (maximum).
Civil liabilities ordered: P28,600.00 as actual/compensatory damages; P1,436,466.30 as loss of earning capacity; P50,000.00 indemnification for death; P50,000.00 moral damages.

Ernesto Ancheta appealed to the Court of Appeals (CA); on November 10, 2000, the CA issued a Resolution dismissing the appeal for failure of the accused-appellant to file his brief.
The CA Resolution became final and executory; entry of judgment was recorded on December 7, 2000.
After record transmission, RTC issued an Order for the arrest of the accused on June 5, 2001.
On June 29, 2001, PHILIPPINE RABBIT BUS LINES, INC. filed a Notice of Appeal. RTC denied due course on July 18, 2001, as the notice was filed after the judgment had become final and executory.
PRBLI moved for reconsideration (Aug 1, 2001) and clarification (Aug 31, 2001); both were denied by the trial court.
PRBLI filed a manifestation citing Ozoa v. Vda. de Madula; on October 17, 2001, the trial court granted relief and gave due course to PRBLI’s appeal, ordering transmission of records to the CA.

The CA considered assignments of error by PRBLI challenging (I) trial court appreciation of facts/evidence, (II) attribution of negligence to Ancheta, and (III) size of damages awarded.
On October 10, 2003, the CA rendered judgment affirming the RTC decision but modified the award of actual damages to P5,000.00; the CA nonetheless stated that the appeal was dismissed on the ground that the RTC decision had long become final and executory and that PRBLI was bound by the decision against the accused.
PRBLI thereafter filed a petition for review on certiorari to the Supreme Court,...(Subscriber-Only)

Whether the conviction of Ernesto Ancheta by the RTC had attained finality and was binding on PHILIPPINE RABBIT BUS LINES, INC. such that PRBLI had no right to appeal the RTC decision.
Whether PHILIPPINE RABBIT BUS LINES, INC. was deprived of its right to due process by its counsel’s alleged failure to notify it of the RTC decision, the CA Resolution, and the RTC Arrest Order, thereby entitling it to challenge the c...(Subscriber-Only)