Case Summary (G.R. No. 82233)
Key Individuals and Context
• Petitioners: Jose Baritua (owner‐operator of JB Bus No. 80) and Edgar Bitancor (driver)
• Respondents: Nicolas Nacario and Victoria Ronda Nacario (parents of the deceased)
• Victim: Bienvenido Nacario (tricycle driver)
• Compulsory Heirs: Alicia Baracena Vda. de Nacario (widow) and the couple’s minor child
Petitioner’s vehicle (JB Bus No. 80) collided with the victim’s tricycle along the national highway in Barangay San Cayetano, Baao, Camarines Sur.
Petitioner’s Claim (Release and Settlement)
• March 27, 1980: Extrajudicial settlement negotiated among petitioners, the bus insurer (PFICI), and Alicia (widow).
• Alicia received P18,500 and executed a Release of Claim and an Affidavit of Desistance, discharging petitioners from “all actions, claims, and demands” arising from the accident.
Filing by the Parents; Trial Court Ruling
• September 2, 1981: Parents filed a complaint for P25,000 (death), P10,000 (tricycle damage), P25,000 (compensatory and exemplary damages), P5,000 (attorney’s fees), and moral damages.
• Trial Court (Court of First Instance) dismissed the complaint, holding the extrajudicial settlement with Alicia (preferred heir) extinguished any liability.
Appellate Court Decision
• Court of Appeals (Dec. 11, 1987) reversed. It held:
– The parents sued in their personal capacity, not as successors of Alicia; her release did not cover their distinct damages.
– Parents proved purchase of the tricycle and funeral expenses; petitioners failed to rebut.
• Award: P10,000 (tricycle), P5,000 (funeral services), P450 (cemetery lot), P55 (oracion adulto), and P5,000 (attorney’s fees).
Issue Before the Supreme Court
Whether the extrajudicial settlement between petitioners and the widow (preferred heir) extinguished petitioners’ obligation to the parents.
Extinguishment of Obligations by Payment (Art. 1231, Civil Code)
• Payment or performance extinguishes obligations.
• Valid payment must be to the creditor or successor in interest (Art. 1240, Civil Code).
• Alicia, as widow and guardian/co‐heir of the minor child, qualified to receive payment and execute a valid release.
Succession and Succession Rights
• Compulsory heirs under the Civil Code (Art. 887): children/descendants first, then parents/ascendants, then spouse.
• Spouse concurs with all classes; par
Case Syllabus (G.R. No. 82233)
Facts
- On November 7, 1979, JB Bus No. 80, driven by Edgar Bitancor and owned by Jose Baritua (petitioners), collided with a tricycle driven by Bienvenido Nacario along the national highway at Barangay San Cayetano, Baao, Camarines Sur.
- The accident resulted in the death of Bienvenido Nacario and his passenger, and damage to the tricycle.
- No criminal proceedings were initiated.
- On March 27, 1980, petitioners and Philippine First Insurance Company, Inc. (PFICI) effected an extrajudicial settlement with Bienvenido’s widow, Alicia Baracena Vda. de Nacario:
- Alicia received ₱18,500.00 as indemnity for her husband’s death and the damaged tricycle.
- Alicia executed a Release of Claim discharging petitioners and PFICI from all actions, claims, and demands arising from the accident.
- Alicia also executed an affidavit of desistance, manifesting her lack of interest in pursuing civil or criminal actions against petitioners.
Procedural History
- On September 2, 1981, Bienvenido’s parents, Nicolas and Victoria Ronda Nacario (private respondents), filed a civil complaint for damages in the Court of First Instance of Camarines Sur.
- They alleged that petitioners had promised to indemnify them at the vigil for their son, but instead settled with Alicia, excluding the parents.
- The complaint prayed for:
- ₱25,000.00 for wrongful death
- ₱10,000.00 for the damaged tricycle
- ₱25,000.00 for compensatory and exemplary damages
- ₱5,000.00 for attorneys’ fees
- Moral damages
- The trial court dismissed the complaint, holding that the extrajudicial payment to Alicia and her child (preferred