HEIRS OF THE LATE TEODORO GUARING JR., plaintiff vs. COURT OF APPEALS, defendant
G.R. No. 108395. March 7, 1997
FACTS:
On November 7, 1987, the car driven by Teodoro Guaring Jr. collided with the Philippine Rabbit Bus driven by Angelo Cuevas and wth a Toyota Cressida Car driven by Eligio Enriquez, along the North Luzon Expressway in San Rafael, Mexico Pampanga.. As a consequence, Guaring died.
The trial court ruled in favor of herein petitioners, but lost in the Court of Appeals where the accused was acquitted based on reasonable doubt. This was because it was found out that the deceased was the one who acted negligently. The accused the claimed appealed in the court that the civil case filed against him be extinguished since the extinguishment of his criminal liability necessarily follows the extinguishment of his civil liability, since his civil liability aroused from his criminal liability. The petitioners disagreed on this ground, claiming that the civil case should pursue. This was then appealed to the Supreme Court.
ISSUE:
Whether or not the civil case must be terminated as a consequence of the termination of the criminal case based on reasonable doubt.
RULING:
The Supreme Court held that the acquittal of the bus driver was based on reasonable doubt, which means that the civil case for damages was not barred since the cause of action of the heirs was based on quasi delict. Even if damages are sought on the basis of crime and not quasi delict, the acquittal of the bus driver will not bar recovery of damages because the acquittal was based not on a finding that he was not guilty but only on reasonable doubt. Thus, it has been held:
The judgment of acquittal extinguishes the liability of the accused for damages only when it includes a declaration that the facts from which the civil might arise did not exist. Thus, the civil liability is not extinguished by acquittal where the acquittal is based on reasonable doubt as only preponderance of evidence is required in civil cases; where the court expressly declares that the liability of the accused is not criminal but only civil in nature as, for instance, in the felonies of estafa, theft, and malicious mischief committed by certain relatives who thereby incur only civil liability; and, where the civil liability does not arise from or is not based upon the criminal act of which the accused was acquitted.
Therefore, the Supreme Court ruled that the proceedings for the civil case of the said incident must continue for the recovery of damages of the victim’s heirs. The case was remanded to the trial court to determine the civil liability of the accused.
