Case Summary (A.C. No. 5485)
Applicable Law and Charges
On July 23, 1993, an Information was filed against Ancheta for reckless imprudence resulting in homicide. The charge arose from an incident that occurred on November 23, 1992, at Barangay Dolores, Capas, Tarlac, where Ancheta's bus collided with Mangawang's jeep, resulting in Mangawang's death. The legal basis for the accusations includes provisions related to reckless imprudence as outlined in the Revised Penal Code and traffic regulations.
Trial Court Proceedings
The Regional Trial Court (RTC) of Capas, Tarlac, Branch 66, found Ancheta guilty on November 12, 1999, sentencing him to imprisonment and ordering him to pay damages amounting to P28,600.00 for actual damages, P1,436,466.30 for loss of earning capacity, and P100,000.00 in total for indemnification and moral damages to Mangawang's heirs.
Appeal to the Court of Appeals
Ancheta's appeal to the Court of Appeals (CA) was dismissed on November 10, 2000, due to his failure to file a brief. This dismissal rendered the RTC's decision final. Consequently, a warrant for Ancheta's arrest was issued on June 5, 2001. The Petitioner, PRBLI, filed its own Notice of Appeal, which was denied by the RTC on grounds of being untimely, as it was considered after the decision had become final.
Employer's Actions and Subsequent Motions
The Petitioner argued that it had not been notified of the RTC's decision or the subsequent orders, due partly to the negligence of the counsel it provided for Ancheta. An urgent motion for reconsideration but subsequent motions for clarification were also denied. Eventually, the RTC allowed the appeal to process on October 17, 2001, where PRBLI raised several assignments of error.
Decision of the Court of Appeals
On October 10, 2003, the CA affirmed the RTC decision but modified the damages awarded to only P5,000.00 for actual damages, explicitly ruling that the decision was binding due to the finality of Ancheta's conviction. Thus, PRBLI was bound by the civil liabilities adjudged against Ancheta.
Petition for Review
Subsequently, PRBLI filed a petition for review, challenging the CA's ruling on two primary grounds: the finality of Ancheta's conviction against it and its right to contest that conviction concerning its civil liabilities. It cited relevant jurisprudence asserting that since the Petitioner was an employer, it had vested interests in the case outcome and should have been given the opportunity to contest the civil judgment directly resulting from its employee's conviction.
Solicitor General's Position
The Office of the Solicitor General countered PRBLI's claims, asserting that PRBLI was not a direct party to the criminal case and hence not entitled to contest the RTC’s judgment, which was res judicata. It argued that any supposed procedural deficiency or negligence on PRBLI’s part was not sufficient grounds to undermine the finality of the conviction.
Supreme Court's Ruling
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...continue readingCase Syllabus (A.C. No. 5485)
Introduction
- This case revolves around a petition for review of the Decision of the Court of Appeals (CA) affirming the conviction of Ernesto Ancheta for reckless imprudence resulting in homicide.
- The case highlights the legal implications of an employer's liability for the actions of an employee and the procedural aspects concerning the right to appeal.
Antecedents
- Ernesto Ancheta was employed as a driver by Philippine Rabbit Bus Lines, Inc. (PRBLI).
- On July 23, 1993, he was charged in the Regional Trial Court (RTC) of Capas, Tarlac, with reckless imprudence resulting in homicide due to an accident occurring on November 23, 1992.
- The Information alleged that Ancheta drove a bus recklessly, colliding with a Toyota jeep driven by Eduardo Mangawang, resulting in Mangawang's death.
Trial Court Proceedings
- The RTC convicted Ancheta on November 12, 1999, sentencing him to an indeterminate prison term and imposing civil liability to the heirs of Mangawang.
- The court ordered Ancheta to pay actual damages, loss of earning capacity, indemnity for death, and moral damages, totaling substantial amounts.
Appeal to the Court of Appeals
- Ancheta's appeal to the CA was dismissed on November 10, 2000, due to his failure to file a brief as the accused-appellant.
- The dismissal of Ancheta's appeal became final and executory, leading to the issuance of an arrest order on June 5, 2001.
Employer's Notice of Appeal
- PRBLI filed a Notice of Appeal on June 29, 2001, after the RTC