Case Summary (G.R. No. 107125)
Facts of the Accident
Petitioner drove his Toyota Starlet after consuming a total of at least twelve bottles of beer between morning and night. At approximately 8:30 p.m. on September 25, 1982, while traveling at speeds estimated between 40 kph (petitioner’s account) and 80–90 kph (jeepney driver’s account) on the Maharlika Highway at Barangay Malvar, Santiago, Isabela, his vehicle collided head-on with an oncoming passenger jeepney. The impact caused petitioner’s car to overturn twice, fatally injuring passenger Ruben Nicolas and injuring others.
Trial Court Ruling
The Regional Trial Court acquitted Manantan of reckless imprudence resulting in homicide, finding that the prosecution failed to establish his guilt beyond reasonable doubt. The court entertained a hypothesis that the collision could have occurred notwithstanding petitioner’s conduct and declined to resolve residual doubt against him. No civil liability was adjudicated at that stage.
Court of Appeals Ruling on Civil Aspect
On appeal limited to civil liability, the Court of Appeals:
- Held that petitioner’s intoxicated driving violated Section 53 of R.A. No. 4136.
- Applied the statutory presumption of negligence under Civil Code Article 2185.
- Ordered indemnity and damages totaling ₱174,400.00 (loss of support ₱104,400; death indemnity ₱50,000; moral damages ₱20,000).
Issues Presented
- Whether acquittal on the criminal aspect barred further inquiry into negligence or constituted double jeopardy.
- Whether civil liability was extinguished by petitioner’s acquittal.
- Whether the Court of Appeals lacked jurisdiction to award damages for failure to pay filing fees under the Manchester doctrine.
Analysis – Double Jeopardy and Scope of Review
- Double jeopardy protects against a second criminal prosecution for the same offense, not against civil enforcement of damages arising from the same act.
- The appellate proceeding addressed only civil liability impliedly instituted with the criminal action (Rule 111, Sec. 1) and did not reopen or amend the criminal acquittal.
- No second criminal prosecution occurred; therefore, no double jeopardy violation.
Analysis – Civil Liability After Acquittal
- Two kinds of acquittal:
a. Acquittal on ground of non-perpetration (bars civil liability ex delicto).
b. Acquittal on reasonable doubt (civil liability remains and may be proven by preponderance of evidence under Civil Code Art. 29). - The trial court’s decision indicated lingering doubt but did not categorically exonerate petitioner from negligence.
- Hence, his acquittal was on reasonable doubt, allowing enforcement of civil liability for the same act or omission.
Analysis – Jurisdiction and Manchester Doctrine
- Under the 1964 Rules (in effect when information was filed in 1983), civil liability was impliedly instituted without specifying damages or assessing filin
Case Syllabus (G.R. No. 107125)
Facts of the Case
- On September 25, 1982, petitioner George Manantan drove his Toyota Starlet after consuming beer with friends during a day of shrimp catching, farm visits, bowling, nightclub drinking, and a late-night meal.
- Manantan, driving at approximately 40 km/h (according to prosecution) or 30 km/h (according to defense) along Maharlika Highway in Malvar, Santiago, Isabela, sideswiped or was struck by an oncoming passenger jeepney with bright lights.
- The collision caused Manantan’s car to overturn twice; Ruben Nicolas, riding in the rear seat, sustained fatal injuries and died at Flores Clinic that same night. Co-passengers suffered minor injuries.
- Two competing versions emerged: the prosecution claimed Manantan was driving negligently on the wrong lane at high speed while intoxicated; the defense asserted the jeepney suddenly swerved into Manantan’s properly-driven lane.
Procedural History
- June 1, 1983: Information for reckless imprudence resulting in homicide filed by the Provincial Fiscal of Isabela (Criminal Case No. 066).
- Arraignment: Manantan pleaded not guilty; trial ensued.
- August 4, 1988: Regional Trial Court, Branch 21, Santiago, Isabela, acquitted Manantan of criminal liability without ruling on civil liability.
- August 8, 1988: Spouses Nicolas appealed the civil aspect only (CA-G.R. CV No. 19240).
- January 31, 1992: Court of Appeals modified the trial court’s judgment, held Manantan civilly liable, and ordered indemnity and damages totaling ₱174,400.00.
- August 24, 1992: Court of Appeals denied Manantan’s motion for reconsideration.
- Petitioner elevated the case to the Supreme Court via petition for review on certiorari.
Issues Presented
- Whether Manantan’s acquittal on reckless imprudence foreclosed further inquiry into negligence or reckless imprudence, amounting to double jeopardy.
- Whether the acquittal extinguished civil liability under Article 29 of the Civil Code and Rule 111 of the Rules of Court.
- Whether the Court of Appeals lacked jurisdiction to award indemnity and damages due to non-payment of filing fees in violation of the Manchester doctrine and relevant Supreme Court circulars.