G.R. No. 167546 - Romero vs. People

Case Summary (G.R. No. 167546)

Factual Background

On April 1, 1999 at around 12:00 noon along Governor Jose Fuentebella Highway at Barangay Hibago, Ocampo, Camarines Sur, a head-on collision occurred between a JC Liner bus driven by Sonny Romero y Dominguez and an Apego taxi with plate PVZ-345. The bus was en route to Naga City while the taxi was proceeding toward the Partido area. The collision produced six fatalities: Gerardo Breis, Sr. (thirty-six years old), Arnaldo Breis (thirteen), Gerardo Breis, Jr. (nine), Rene Montes (fourteen), Erwin Breis (seven), and Jimmy Padua (forty-one). Survivors included Edwin Breis and his son Edmund Breis, both sustaining serious injuries.

Trial Court Proceedings

Criminally, petitioner was charged with reckless imprudence resulting in multiple homicide and multiple serious physical injuries with damage to property in the MTC of Ocampo, Camarines Sur. After trial, the MTC acquitted petitioner in a decision dated November 9, 2000, but held him civilly liable and ordered payment of P3,541,900 to the heirs of the victims by way of actual damages, civil indemnity for death, moral damages, temperate damages, and loss of earning capacity. Petitioner appealed under Rule 42 to the RTC of Pili, Camarines Sur, which on July 17, 2001 affirmed the MTC judgment in toto. Petitioner then appealed to the CA, which on March 3, 2005 rendered the assailed decision affirming the RTC. Petitioner invoked Rule 45 to bring the case to the Supreme Court.

The Parties' Contentions

Petitioner asserted that his acquittal should have absolved him from any civil liability and further contended that he should be entirely exonerated because the taxi at the time of the accident was being driven by Gerardo Breis, Sr., and not by the regular driver, Jimmy Padua, a fact which petitioner argued was in violation of insurance and transportation laws. The respondents maintained the judgments below which upheld civil liability despite criminal acquittal and asserted that the evidence established that Jimmy Padua, not Gerardo Breis, Sr., was driving the taxi at the time of the collision.

Issue Presented

The principal legal questions were whether an acquittal of the accused in criminal proceedings necessarily extinguishes civil liability arising from the same act and whether the factual determination of the person driving the taxi at the time of the accident warranted reversal of the factual findings of the lower courts.

Ruling of the Supreme Court (Disposition)

The petition was denied. The Supreme Court affirmed the judgments of the MTC, the RTC, and the CA that, while petitioner was acquitted of criminal liability for reckless imprudence because the prosecution failed to prove guilt beyond reasonable doubt, petitioner remained civilly liable to the heirs and injured parties under the preponderance of evidence standard. Costs were imposed against petitioner.

Legal Basis and Reasoning

The Court reiterated the rule that, as a general proposition, every person criminally liable is also civilly liable, citing Revised Penal Code, Art. 100 and the dual character of a crime as both an offense against the State and an offense against private persons injured thereby. The Court examined Section 2, Rule 111 and Section 2, Rule 120, Rules of Court, and emphasized their plain terms: extinction of the penal action does not carry with it extinction of the civil action, and a civil action based on delict is deemed extinguished only where a final judgment in the criminal action expressly finds that the act or omission from which the civil liability may arise did not exist. The Court noted that an acquittal must state whether the prosecution’s evidence absolutely failed or merely failed to prove guilt beyond reasonable doubt, and in either case the judgment must determine if the act or omission from which civil liability might arise did not exist. The Court relied on established precedents that an accused may be acquitted on reasonable doubt and yet still be ordered to pay civil damages in the same proceeding because civil liability requires proof by a preponderance of evidence, which is a lower standard than proof beyond reasonable doubt. The Court concluded that the MTC acquitted petitioner because the prosecution did not prove wanton or reckless driving beyond reasonable doubt, but did not find that the negligent act did not exist; accordingly, civil liability could properly be imposed where negligence was shown by preponderant evidence.

Findings on the Identity of the Taxi Driver and Scope of Review

The Supreme Court observed that the MTC, the RTC, and the CA uniformly found that Jimmy Padua, and not Gerardo Breis, Sr., was driving the taxi

Case Syllabus (G.R. No. 167546)

Parties

Sonny Romero y Dominguez was the petitioner and driver of the JC Liner involved in the collision.
People of the Philippines, Isabel Padua, Regina Breis, Minerva Montes, and Ofelia Belando Breis were the respondents and private claimants.
The surnames of respondents Regina Breis and Ofelia Belando Breis were erroneously stated as "Bries" in the petition caption.

Facts

On April 1, 1999 at around 12:00 noon, the JC Liner driven by petitioner and the Apego Taxi driven by Jimmy Padua collided head-on along Governor Jose Fuentebella Highway at Barangay Hibago, Ocampo, Camarines Sur.
The JC Liner bore Plate No. EAW-533 and Body No. 1019, and the Apego Taxi bore Plate No. PVZ-345.
The bus was bound for Naga City while the taxi was proceeding toward the Partido Area.
The collision caused the deaths of Gerardo Breis, Sr. (36), Arnaldo Breis (13), Gerardo Breis, Jr. (9), Rene Montes (14), Erwin Breis (7), and Jimmy Padua (41).
Edwin Breis and his son Edmund Breis survived but sustained serious injuries.

Procedural History

Petitioner was criminally charged with reckless imprudence resulting in multiple homicide and multiple serious physical injuries with damage to property in the Municipal Trial Court (MTC) of Ocampo, Camarines Sur.
The MTC acquitted petitioner of the criminal charge in a decision dated November 9, 2000, but held him civilly liable and awarded P3,541,900 in various damages.
Petitioner appealed to the Regional Trial Court (RTC) of Pili, Camarines Sur, which affirmed the MTC judgment on July 17, 2001.
Petitioner elevated the case to the Court of Appeals (CA) under Rule 42, Rules of Court, and the CA affirmed the lower courts' rulings on March 3, 2005.
Petitioner filed a petition for review under Rule 45, Rules of Court before the Supreme Court.

Issues Presented

Whether petitioner’s acquittal in the criminal case extinguished his civil liability arising from the collision.
Whether the taxi was lawfully driven by Jimmy Padua at the time of the accident or by Gerardo Breis, Sr., with the attendant argument on insurance and transportation law violations.

Trial Courts' Findings

The MTC found that the prosecution failed to prove wanton and reckless driving by petitioner beyond reasonable doubt due to highway conditions and the short distance prior to collision, but held petitioner civilly liable.
The RTC observed that the MTC did not find that the act giving rise to civil liability did not exist and affirmed civil liability.
The CA agreed that petitioner was acquitted because the evidence failed to prove guilt beyond reasonable