Case Summary (G.R. No. 159611)
Background and Criminal Proceedings
Carlos Bangkili was charged with the crime of homicide and pleaded guilty on November 21, 1960, receiving a sentence from the Court of First Instance of Mountain Province. However, the sentencing did not address the civil indemnity owed to the deceased’s heirs, prompting the plaintiffs to file a civil suit against both Carlos and his mother, Victoria, seeking damages.
Trial Court Decision and Dismissal
The trial court dismissed the complaint against Victoria Bangkili, holding that under Article 101 of the Revised Penal Code, she could not be held civilly liable for her son’s criminal act since he was already 19 years old. The court reasoned that Article 2180 of the New Civil Code was not applicable, as it pertains to liability arising from quasi-delicts rather than criminal acts. The court rendered a judgment against Carlos, awarding the plaintiffs a total of P8,000, which included indemnity, moral damages, incurred expenses, attorney's fees, and costs.
Motion for Reconsideration and Appeal
Following the dismissal against Victoria, the plaintiffs sought a reconsideration, which was denied. This led them to appeal the decision regarding Victoria's civil liability. The liability imposed on Carlos Bangkili was not contested by either party, making the mother's responsibility the sole focus of the appeal.
Legal Issues and Precedents Considered
The key issue is whether Victoria Bangkili, as the mother and custodian of Carlos during the commission of the offense, is liable alongside her son for the damages awarded. The court reviewed previous cases where similar matters were adjudicated, including Exconde vs. Capuno, Araneta vs. Arreglado, and Fuellas vs. Cadano. These precedents established the principle that a parent could be held subsidiary liable for damages caused by their minor child, particularly when the child acts with discernment.
Court's Reasoning and Application of the Law
The ruling emphasized that Article 2180 of the Civil Code applies even when the child involved is older than 18, provided that the mother is found to have failed in exercising the proper care and vigilance. It was asserted that a parent cannot avoid liability simply by arguing the age and maturity of the child. The court found no evide
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Case Background
- The plaintiffs in this case are Linday Paleyan, the widow of Balos Paleyan, and their minor children: Teresa, Fortunato, Venancio, and Jose.
- The defendants are Carlos Bangkili, who was accused of killing Balos Paleyan, and his mother, Victoria Bangkili.
- At the time of the homicide, Carlos Bangkili was a 19-year-old minor living with his mother.
Criminal Proceedings
- Carlos Bangkili was charged with homicide and less serious physical injuries in Criminal Case No. 898 in the Court of First Instance of Mountain Province.
- On November 21, 1960, Carlos Bangkili pleaded guilty and was sentenced, but no civil indemnity for the heirs of the deceased was mentioned in the decision.
Civil Action Filed
- On April 3, 1961, the plaintiffs initiated a civil action seeking damages against both Carlos and Victoria Bangkili.
- Following a trial, the court dismissed the complaint against Victoria Bangkili, ruling that under Article 101 of the Revised Penal Code, she could not be held civilly liable for her son’s actions.
- The court ruled in favor of the plaintiffs against Carlos Bangkili, awarding specific amounts for indemnity, moral damages, expenses, attorney's fees, and costs.
Ruling on Victoria Bangkili's Liability
- The trial court's dismissal of the complaint against Victoria Bangkili was based o