Case Summary (G.R. No. L-10542)
Factual Background
On July 25, 1951, a truck owned by Zacarias Sarabia and driven by Emilio Celeste was involved in a collision with a truck operated by Juan Cadungon, owned by Maria M. Lim. The collision resulted in the death of Gaudencio Basco, a passenger in Sarabia's truck. Basco's widow and heirs filed for damages against Sarabia and Celeste on April 19, 1955. Subsequently, Sarabia and Celeste filed a third-party complaint against Juan Cadungon and Maria M. Lim, claiming that Lim's truck was responsible for the accident.
Motion to Dismiss
Maria M. Lim sought to dismiss the third-party complaint on the grounds that there was no cause of action against her and that the action was barred by prescription due to the quasi-delict nature of the claim, which has a prescriptive period of four years as per Article 1146 of the Civil Code. On July 11, 1955, the court granted Lim's motion to dismiss.
Ruling on Prescription
The court ruled that the action against Lim prescribed because the collision occurred on July 25, 1951, and the amended third-party complaint was filed over four years later, in December 1955. The court held that the four-year period for actions based on quasi-delict begins from the date of the damage, aligning with Article 1146 of the Civil Code. Since the collision took place well before the filing of the third-party complaint, the claim was not enforceable.
Nature of Claims and Actions
The court clarified that the third-party complaint against Lim could only be valid if the underlying action was not already barred by prescription. The argument made by the appellants that the four-year period should be counted from the filing date of their complaint against Basco's heirs (April 19, 1955) was rejected. The court highlighted that such a claim should have been made within four years from the date of the collision, emphasizing the principle that actions based on quasi-delicts are independent of any ensuing criminal proceedings.
Solidarity of Liability
The ruling also discussed the nature of liability under Article 2194, which states that the responsibility of multiple parties in a quasi-delict is solidary. This means that each liable party can defend themselves assertively against the claims made by the creditor, including invoking defenses related to prescription. This solidary nature does not allow for indirect claims against a party that can no longer be held accountable due to the expiration of the prescriptive period.
Implications of Criminal Proceedings
It was noted that criminal prosecution against the drive
...continue readingCase Syllabus (G.R. No. L-10542)
Case Background
- On July 25, 1951, a collision occurred between a truck owned by Zacarias Sarabia, driven by Emilio Celeste, and another truck belonging to the Mary Lim Line.
- The collision resulted in the death of Gaudencio Basco, a passenger in Sarabia's truck.
- Following the incident, on April 19, 1955, Basco's widow and heirs initiated a complaint against Zacarias Sarabia and Emilio Celeste, seeking compensation and damages.
- On July 11, 1955, Sarabia and Celeste filed a third-party complaint against Juan Cadungon, the driver of the Mary Lim truck, and subsequently amended it to include Maria M. Lim as the owner of the truck.
Motion to Dismiss
- Maria M. Lim filed a motion to dismiss the third-party complaint on two grounds:
- Lack of cause of action against her.
- The action, classified as a quasi-delict, had prescribed as per the provisions of law.
- The trial court sustained the motion, resulting in the dismissal of the complaint against Maria Lim.
Appeal and Legal Analysis
- The appellants contested the dismissal, arguing that the period of prescription should commence from the date the main action was filed (April 19, 1955), not from the date of the collision.
- The court analyzed the nature of the action, confirming it was based on a quasi-delict, which prescribes in four years