Case Summary (G.R. No. 110170)
Key Dates
- July 1982: Petitioners file Criminal Case No. TG-907-82 against corporate officers for destruction by inundation (Art. 324, Revised Penal Code).
- February 22, 1983: Petitioners file Civil Case No. TG-748 for damages and preliminary injunction.
- April 26, 1984: Trial court suspends the civil proceedings pending resolution of the criminal case.
- August 27, 1984: Trial court dismisses the civil case for lack of jurisdiction under Section 3(a), Rule 111 of the Rules of Court.
- February 17, 1986: Intermediate Appellate Court affirms the dismissal.
- May 19, 1986: Appellate court denies petitioners’ motion for reconsideration.
- November 6, 1990: Supreme Court issues its decision reversing the dismissal.
Applicable Law
- 1987 Philippine Constitution (Art. III, Sec. 1; Art. XII, Sec. 11 on property rights)
- Civil Code of the Philippines:
• Article 2176 (liability for quasi-delict)
• Article 2177 (distinctness of civil liability from penal liability)
• Article 431 (restriction on use of one’s property that injures another) - Rules of Court, Rule III, Section 3(a): prohibition on instituting a civil action arising from the same offense until after final judgment in the criminal case.
Facts Alleged in the Civil Complaint
- Within its property, the respondent corporation constructed elaborate waterpaths, culverts and an artificial lake that redirected surface and stormwater onto petitioners’ land.
- The inundation allegedly:
- Eroded and converted portions of petitioners’ fields into deep canals unfit for cultivation;
- Washed away fences;
- Endangered the lives of petitioners, their laborers, and caused a drowning fatality;
- Damaged crops, plants, and other improvements.
Legal Issue
Whether a civil action for damages based on acts or omissions constituting a quasi‐delict (Articles 2176 and 2177, Civil Code) may proceed independently of a criminal prosecution for the same factual acts, notwithstanding Section 3(a), Rule III of the Rules of Court.
Analysis
Nature of the Civil Action
- The complaint’s allegations sound in quasi‐delict: petitioners allege negligence in the construction and maintenance of water‐conducting structures that caused direct harm.
- All elements of quasi‐delict are present: wrongful act or omission, fault or negligence, damage, and proximate causation.
Distinctness from Criminal Liability
- Article 2176 imposes civil liability for quasi‐delicts even if the act is punishable under criminal law.
- Article 2177 confirms that civil liability for quasi‐delicts is entirely separate and independent from penal liability; the offended party may pursue both actions but recover only once.
- Precedents (Samson v. Dionisio; Castillo v. Court of Appeals; Azucena v. Potenciano) establish that civil claims for quasi‐delict proceed regardless of the pendency or outcome of criminal proceedings, absent a judicial finding that the fact underlying the claim did not exist.
Inapplicability of Section 3(a), Rule III
- That provision applies to civil actions “arising from the same offense” prosecuted criminally.
- Quasi‐delict is a separate civil remedy under the Civil Code and does not constitute the “same offense” as the penal charge under Article 324, Revised Penal Code.
Property‐Use Principle
- Under Article 431, an owner must use property so as not to injure
Case Syllabus (G.R. No. 110170)
Antecedent Facts
- Petitioners Emmanuel and Natividad Andamo own a parcel of land in Biga (Biluso), Silang, Cavite, adjacent to the private respondent corporation’s property.
- Respondent Missionaries of Our Lady of La Salette, Inc. constructed on its land waterpaths, inter-connected culverts beneath fences and gates, and an artificial lake with a soil base fed by galvanized pipes.
- The waterworks allegedly caused annual inundation and seepage onto petitioners’ land, resulting in:
- Erosion of soil into deep, wide canals unfit for cultivation.
- Destruction and wash-away of costly fences.
- Danger to the lives of petitioners, their laborers, and a drowning incident.
- Exposure and destruction of plants and other improvements.
Trial Court Proceedings
- July 1982: Petitioners filed Criminal Case No. TG-907-82 under Art. 324, Revised Penal Code, against corporate officers for destruction by inundation.
- February 22, 1983: Petitioners instituted Civil Case No. TG-748 for damages and sought a writ of preliminary injunction.
- March 11, 1983: Respondent corporation filed its answer and opposed injunctive relief.
- April 26, 1984: RTC suspended hearings in the civil case pending resolution of the criminal case.
- August 27, 1984: RTC dismissed the civil action for lack of jurisdiction pursuant to Section 3(a), Rule III of the Rules of Court, holding that no civil action may proceed until final judgment in a related criminal case.
Intermediate Appellate Court Proceedings
- Petitioners appealed the RTC’s dismissal to the Intermediate Appellate Court (First Civil Cases Division).
- February 17, 1986: The Appellate Court affirmed the