Case Digest (G.R. No. 74613)
Facts:
- Petitioners: Spouses Dr. Fidel Calalang and Dra. Maria Gener Calalang, along with their son Ferdinand Calalang.
- Respondents: Heirs of Erlinda Gruta.
- Incident Date: October 31, 1981; Erlinda Gruta, a 15-year-old househelper, died from malathion poisoning while employed by the Calalang family in Bulacan.
- Allegation: Ferdinand Calalang was charged with murder for allegedly poisoning Erlinda.
- Investigation: Conducted by the National Bureau of Investigation (NBI); case referred to the Office of the Provincial Fiscal in Malolos, Bulacan.
- Evidence: Presented by Juanita Gruta, mother of the deceased, including a necropsy report.
- Outcome of Criminal Case: Dismissed due to lack of prima facie evidence.
- Civil Case Filed: On June 8, 1983, heirs of Erlinda Gruta sought damages against Ferdinand and his parents, claiming joint and several liability for various damages totaling P152,000.
- Trial Court Decision: Dismissed the case on March 30, 1984, for lack of cause of action.
- Appeal: Intermediate Appellate Court (IAC) reversed the dismissal on June 28, 1985, remanding for further proceedings.
- Petitioners' Motion: Denied on April 28, 1986, leading to a petition for review on certiorari.
Issue:
- (Unlock)
Ruling:
- The Supreme Court affirmed the IAC's decision, remanding the case for further proceedings.
- The case agains...(Unlock)
Ratio:
- The Supreme Court determined that the trial court's dismissal was unjustified solely on the basis of lack of cause of action, as the complaint sufficiently alleged civil liability from Ferdinand Calalang's alleged criminal act.
- The Court emphasized that the dismissal of the criminal case does not extinguish civil liability unless a final judgment negates the facts supporting the civil claim.
- It noted that civil actions can proceed independently of cri...continue reading
Case Digest (G.R. No. 74613)
Facts:
The case involves the petitioners, Spouses Dr. Fidel Calalang and Dra. Maria Gener Calalang, along with their son Ferdinand Calalang, against the respondents, the Heirs of Erlinda Gruta. The events leading to the case began on October 31, 1981, when Erlinda Gruta, a 15-year-old househelper from Samar, died from malathion poisoning while employed by the Calalang family in Bulacan. Ferdinand Calalang was charged with murder for allegedly poisoning her. The National Bureau of Investigation (NBI) investigated the incident, and the case was subsequently referred to the Office of the Provincial Fiscal in Malolos, Bulacan, for preliminary investigation. The mother of the deceased, Juanita Gruta, presented evidence, including a necropsy report, but the complaint against Ferdinand was dismissed due to a lack of prima facie evidence.
Almost two years after Erlinda's death, on June 8, 1983, the heirs of Erlinda Gruta filed a civil case for damages against Ferdinand Calalang and his parents, claiming joint and several liability for actual and compensatory damages amounting to P50,000 for moral damages, P72,000 for loss of earnings, and P30,000 for attorney's fees, among other expenses. The Regional Trial Court of Manila dismissed the case on March 30, 1984, citing a lack of cause of action. However, the Intermediate Appellate Court (IAC) reversed this decision ...