Case Summary (G.R. No. 73271)
Procedural History
Laroya’s criminal complaint (Criminal Case No. 002-99) was under preliminary investigation when Casupanan and Capitulo filed Civil Case No. 2089 before the Municipal Circuit Trial Court (MCTC) of Capas. The MCTC granted Laroya’s motion to dismiss for alleged forum-shopping (March 26, 1999) and denied reconsideration (May 7, 1999). Petitioners then sought certiorari relief from the Regional Trial Court (RTC), which dismissed their petition (December 28, 1999) and denied reconsideration (August 24, 2000). They elevated the matter to the Supreme Court.
Legal Issue
Whether an accused in a pending criminal case for reckless imprudence may simultaneously and independently file a separate civil action for quasi-delict against the private complainant without constituting forum-shopping.
Nature of Dismissal and Proper Remedy
The MCTC’s dismissal order did not state it was “with prejudice” and therefore constituted a dismissal without prejudice under Administrative Circular No. 04-94. Such an order is not appealable; the proper remedy is a special civil action under Rule 65. The RTC’s ruling that petitioners should have appealed rather than seek certiorari was erroneous.
Distinct Causes of Action and Absence of Forum-Shopping
Forum-shopping involves multiple suits by the same parties on the same cause of action seeking identical relief. Here, the criminal charge under the Revised Penal Code addresses punishable negligence, while the civil action under Civil Code Articles 2176–2177 addresses quasi-delictual liability. These are separate causes of action with distinct reliefs, precluding a finding of forum-shopping and permitting both actions to proceed independently.
Interpretation of Rule 111, Rules on Criminal Procedure
Under the 2000 Rules on Criminal Procedure, Rule 111:
• Section 1 deems only the civil action for ex-delicto liability instituted with the criminal case; independent civil actions under Articles 32, 33, 34, and 2176 are not deemed instituted and may be filed separately without reservation.
• Section 2’s suspension rule applies solely to ex-delicto actions instituted or reserved.
• Section 3 expressly allows the offended party to pursue an independent civil action under Articles 32, 33, 34, and 2176, subject only to the prohibition against double recovery.
• Paragraph 6, Section 1 bars the accused from counterclaims in the criminal case and mandates that any possible coun
Case Syllabus (G.R. No. 73271)
Facts
- Two vehicles collided in Capas, Tarlac: one driven by respondent Mario Llavore Laroya and the other owned by petitioner Roberto Capitulo and driven by petitioner Avelino Casupanan.
- Laroya filed Criminal Case No. 002-99 for reckless imprudence resulting in damage to property, then at preliminary investigation.
- Casupanan and Capitulo filed Civil Case No. 2089 for quasi-delict damages against Laroya.
Proceedings in the MCTC
- Laroya moved to dismiss the civil action for forum-shopping due to the pending criminal case.
- On March 26, 1999, the Municipal Circuit Trial Court (MCTC) granted dismissal of Civil Case No. 2089.
- Casupanan and Capitulo moved for reconsideration, arguing the civil action was independent; MCTC denied it on May 7, 1999.
- The MCTC order did not expressly state whether the dismissal was with prejudice.
Petition for Certiorari Before the RTC
- Petitioners filed Special Civil Action No. 17-C (99) under Rule 65 before the Regional Trial Court of Capas, Tarlac, Branch 66.
- They sought to annul the MCTC orders for lack of power to dismiss a separate civil action on quasi-delict.
RTC Resolution and Reconsideration
- On December 28, 1999, the RTC dismissed the certiorari petition as the MCTC order was final and appealable.
- The RTC held that certiorari cannot substitute for an appeal and any error was a mere error of judgment, not an abuse of discretion.
- Petitioners’ motion for reconsideration was denied on August 24, 2000.
Issue
- Whether an accused in a pending criminal case for reckless imprudence may simultaneously and independently file a separate civil action for quasi-delict against the private complainant in that criminal case.
Parties’ Contentions
- Petitioners’ Arguments:
- Civil Case No. 2089 operates as a valid counterclaim in a separate civil action under Articles 31 and 2176 of the Civil Code.
- Quasi-delict liability is distinct from criminal liability for reckless imprudence.
- The civil acti