Primary Holding
Article 33 of the Civil Code permits a civil action for physical injuries to proceed independently of a criminal case, regardless of whether the offense is classified as physical injuries, frustrated homicide, or another crime involving bodily harm.
Background
After Tomas Valenton Jr. was convicted of frustrated homicide for attacking Carandang, Carandang filed a civil suit for damages. The trial court suspended the civil case pending the criminal appeal. Carandang challenged this suspension via certiorari.
History
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September 1, 1953: Court of First Instance of Batangas convicted Valenton Jr. of frustrated homicide.
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Post-conviction: Carandang filed a civil case in Manila for damages.
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Defendants moved to suspend the civil case pending the criminal appeal.
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Trial court granted the suspension; Carandang’s motion for reconsideration was denied.
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Supreme Court granted certiorari, reversing the trial court’s order.
Facts
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1.
Valenton Jr. inflicted bodily injuries on Carandang, leading to a criminal conviction for frustrated homicide.
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2.
Carandang filed a civil action for actual and moral damages against Valenton Jr. and his parents.
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3.
The trial court suspended the civil case until the criminal appeal concluded.
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4.
Carandang argued Article 33 of the Civil Code allowed the civil case to proceed independently.
Arguments of the Petitioners
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1.
Article 33 allows a civil action for physical injuries to proceed independently of criminal prosecution.
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2.
“Physical injuries” in Article 33 refers to bodily harm in a generic sense, not the specific crime under the Revised Penal Code.
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3.
The civil case should not be delayed by the pending criminal appeal.
Arguments of the Respondents
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1.
“Physical injuries” in Article 33 refers only to the specific crime defined in the Revised Penal Code.
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2.
Since the conviction was for frustrated homicide (not physical injuries), the civil action must await the criminal appeal.
Issues
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1.
Whether the term “physical injuries” in Article 33 of the Civil Code is limited to the specific crime under the Revised Penal Code or encompasses any bodily injury, enabling the civil case to proceed independently.
Ruling
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1.
The Supreme Court ruled that “physical injuries” in Article 33 is interpreted generically, covering any bodily injury irrespective of the criminal charge (e.g., frustrated homicide).
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2.
The civil action is independent and requires only a preponderance of evidence.
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3.
The trial court erred in suspending the civil case; the order was revoked, and the civil trial was ordered to proceed.
Doctrines
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1.
Statutory Construction: Terms in statutes should be interpreted consistently; “physical injuries” aligns with generic bodily harm, not technical criminal definitions.
Key Excerpts
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1.
“The term ‘physical injuries’ should be understood to mean bodily injury, not the crime of physical injuries.”
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2.
“The civil action should lie whether the offense committed is that of physical injuries, or frustrated homicide, or attempted homicide, or even death.”
Precedents Cited
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1.
Bixby vs. Sioux City (164 N.W. 641): Cited to analogize that claims for death from personal injury fall under the same statutory category as non-fatal injuries.
Statutory and Constitutional Provisions
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1.
Article 33 of the Civil Code: Allows independent civil actions for defamation, fraud, or physical injuries, interpreted broadly.