Case Summary (G.R. No. 127934)
Background of the Incident
The vehicular accident occurred on June 1, 1984, involving a truck owned by Ace Haulers Corporation, driven by Jesus dela Cruz, which fatally struck Fidel Abiva after a jeepney owned by Isabelito Rivera, driven by Rodolfo Parma, initially collided with Abiva on a motorcycle. The incident prompted a criminal case for reckless imprudence resulting in homicide against both drivers, alongside civil actions for damages initiated by Ederlinda Abiva, the widow of the deceased.
Legal Actions Initiated
On July 27, 1984, a criminal information was filed against the drivers. Subsequently, on March 11, 1985, Ederlinda Abiva initiated a separate civil action for damages against the drivers, the vehicle owners, and others involved in the case. She sought actual and moral damages, attorney's fees, and a writ of preliminary attachment against the defendants’ properties.
Motion to Dismiss and Trial Court's Ruling
In January 1986, Ace Haulers Corporation and Jesus dela Cruz moved to dismiss the civil action, citing the pending criminal case and the prohibition against dual civil actions under the 1985 Rules on Criminal Procedure. However, Ederlinda Abiva opposed the motion, asserting her right to pursue an independent civil action. The trial court dismissed her case, determining that no civil action could proceed independently of the criminal case.
Intervention of Intermediate Appellate Court
Ederlinda Abiva sought relief from the dismissal through a petition for certiorari, which resulted in the Intermediate Appellate Court reversing the trial court's decision. The Supreme Court later denied the petition of Ace Haulers Corporation and Dela Cruz for lack of sufficient grounds, thus remanding the case back to the trial court for further proceedings.
Trial Court Proceedings Post-Reconstitution
In March 1992, following a fire that destroyed records, the trial court reconstituted the case. By July 1992, the guilty verdict was rendered against both drivers in the criminal case, imposing penalties and damages to the heirs of Fidel Abiva.
Civil Trial Outcome
During the civil case trial, Ederlinda Abiva presented testimonial and documentary evidence, including her claims of actual damages stemming from her husband's death, his earnings, and related expenses. The trial court eventually ruled against Ace Haulers Corporation, affirming the plaintiff's entitlements for moral and exemplary damages, along with attorney’s fees.
Appeals and Court of Appeals Decision
The petitioner appealed the trial court ruling to the Court of Appeals, which upheld the trial court's decision except for the exemplary damages, which were deleted. The appellate court determined that Ederlinda Abiva had the right to seek damages for the death of her husband.
Legal Principles Considered
The case hinged on the legal principles governing civil liability arising
...continue readingCase Syllabus (G.R. No. 127934)
Case Overview
- The case involves an appeal via certiorari by Ace Haulers Corporation against the decision of the Court of Appeals, which affirmed the ruling of the Regional Trial Court of Quezon City, Branch 106, save for the deletion of exemplary damages.
- The trial court's decision ordered Ace Haulers Corporation to pay the respondent, Ederlinda Abiva, various amounts for actual and moral damages, as well as attorney's fees.
Background Facts
- The incident in question occurred on June 1, 1984, involving a truck owned by Ace Haulers Corporation, driven by its employee Jesus dela Cruz, and a jeepney owned by Isabelito Rivera, driven by Rodolfo Parma.
- The vehicular accident resulted in the death of Fidel Abiva, the rider of a motorcycle that was struck and subsequently run over by the truck.
- Fidel Abiva left behind his wife, Ederlinda Abiva, and three children.
Legal Proceedings
- A criminal information for reckless imprudence resulting in homicide was filed against both drivers on July 27, 1984.
- In parallel, Ederlinda Abiva filed a civil action for damages against the drivers and the owners of the vehicles on March 11, 1985, requesting various forms of damages and a writ of preliminary attachment.
- Ace Haulers Corporation and Jesus dela Cruz filed a motion to dismiss, arguing that the civil action was not permissible while the criminal case was pending.
- The trial court dismissed the civil action, leadin