Laura Corpus, et al. vs. Felardo Paje and The Victory Liner Transportation Co., Inc.

The acquittal of an accused in a criminal case for reckless imprudence on the ground that the fact from which civil liability might arise did not exist is a bar to a subsequent civil action for damages based on the same act (delict). Alternatively, if the civil action is founded on quasi-delict, it must be filed within the four-year prescriptive period from the date of the incident, which is not interrupted by the institution of the criminal action.

The case originated from a vehicular accident on December 23, 1956, in Lubao, Pampanga. A passenger bus owned by Victory Liner Transportation Co., Inc. and driven by Felardo Paje collided with a jeep driven by Clemente Marcia. The collision resulted in the death of Clemente Marcia and physical injuries to two other individuals. This event triggered both criminal and civil proceedings to determine liability for the death and damages.

• On December 23, 1956, a collision occurred between a Victory Liner bus driven by Felardo Paje and a jeep driven by Clemente Marcia, resulting in Marcia's death.
• A criminal case for homicide and double serious physical injuries through reckless imprudence was filed against Paje. The heirs of Marcia reserved their right to institute a separate civil action.
• On November 7, 1960, the Court of First Instance convicted Paje. Paje appealed this conviction to the Court of Appeals.
• On November 21, 1961, while the criminal appeal was pending, Marcia's heirs filed a separate civil action for damages against Paje and Victory Liner in the Court of First Instance of Rizal. This was four years and eleven months after the collision.
• On November 9, 1962, the Court of Appeals acquitted Paje, finding that the reckless imprudence charged against him did not exist and that the collision was a case of pure accident.
• The defendants moved to dismiss the civil case, arguing it was barred by the acquittal. The trial court later dismissed the complaint, not on the ground of the acquittal, but on the ground that the action, being based on a quasi-delict, had prescribed.

The petitioners contended that the lower court erred in dismissing their complaint for damages.

• The respondents argued that the civil action was barred by the acquittal of defendant Felardo Paje in the criminal action by the Court of Appeals.
• The respondents raised the special defense that the plaintiffs' cause of action, if based on a quasi-delict, had prescribed because the complaint was filed four years and eleven months after the collision.

• Procedural Issues:
  • N/A
• Substantive Issues:
  • Whether the acquittal of the accused in a criminal case for reckless imprudence, based on a finding that the act of negligence did not exist, bars a separate civil action for damages arising from the same act.
  • Whether an action for damages based on a quasi-delict has a prescriptive period of four years, and if the institution of a criminal action interrupts this period.

• Procedural:
  • N/A
• Substantive:
  • Yes, the acquittal of Felardo Paje barred the civil action for damages based on delict. The Court ruled that since the acquittal was based on a finding that the reckless imprudence or criminal negligence did not exist and the event was a pure accident, the civil action arising from the same alleged crime was extinguished. The Court clarified that reckless imprudence is not one of the crimes enumerated in Article 33 of the Civil Code that allows for an independent civil action. Therefore, the general rule applies: the extinction of the criminal action on the ground that the fact did not exist also extinguishes the civil liability.
  • Yes, the action based on quasi-delict had prescribed. The Court held that, assuming arguendo the civil action was based on a quasi-delict, the trial court was correct in finding that it had prescribed. An action upon a quasi-delict must be filed within four years from the date of the incident, as per Article 1146 of the Civil Code. The prescriptive period began on December 23, 1956, and was not interrupted by the filing of the criminal case. Since the civil complaint was filed four years and eleven months later, it was time-barred.

• Extinction of Civil Liability Arising from Delict — This doctrine states that civil liability arising from a crime is extinguished if a final judgment in the criminal case declares that the fact from which the civil liability might arise did not exist. In this case, the Court of Appeals' finding that there was no reckless imprudence and the collision was a "pure accident" was a declaration that the criminal act did not exist, thereby extinguishing the civil liability of Felardo Paje that was based on that same act.
• Independent Civil Action under Article 33, Civil Code — This principle allows for a separate civil action for damages arising from defamation, fraud, and physical injuries, which can proceed independently of the criminal case. The Court held this doctrine inapplicable because the offense charged was "reckless imprudence," which is a form of criminal negligence and is not one of the specific crimes listed in Article 33. The Court reasoned that the offense is the negligent act itself, not its result (homicide).
• Prescription of Action based on Quasi-Delict — An action to recover damages based on a quasi-delict must be filed within four years from the day the cause of action accrued. The Court applied this rule to the alternative theory of the case, holding that the four-year period started from the date of the collision and was not interrupted by the filing of the criminal action. Since the plaintiffs filed their complaint beyond this period, their action had prescribed.

• "The acquittal of the defendant Felardo Paje by the Court of Appeals in the criminal action on the ground that the reckless imprudence or criminal negligence charged against him did not exist and that the collision was a case of pure accident, was a bar to the civil action for damages for the death of Clemente Marcia, which action was based upon the same criminal negligence of which the defendant Felardo Paje was acquitted in the criminal action."
• "As reckless imprudence or criminal negligence is not one of the three crimes mentioned in Article 33 of the Civil Code, there is no independent civil action for damages that may be instituted in connection with said offense."
• "Assuming, arguendo, that the civil action for damages for the death of Clemente Marcia was based upon a quasi-delict, the trial court's finding that on that basis the action had prescribed is correct. An action upon a quasi-delict must be instituted within four (4) years (Article 1146, Civil Code). The four-year prescriptive period began to run from the day the quasi-delict was committed... and the running of the said period was not interrupted by the institution of the criminal action for reckless imprudence."

• Chantangco vs. Abaroa — Cited as the primary authority for the principle that a verdict of acquittal in a criminal case must carry with it an exemption from civil responsibility when the acquittal is based on a finding that the act itself did not exist.
• People vs. Buan — Referenced to explain that the offense of criminal negligence under the Revised Penal Code lies in the execution of an imprudent or negligent act, not in the result. This supported the Court's reasoning that "reckless imprudence resulting in homicide" is not the crime of "homicide" or "physical injuries" covered by Article 33 of the Civil Code.
• Paulan vs. Sarabia — Cited as precedent for the rule that the institution of a criminal action does not interrupt the prescriptive period for filing a separate civil action based on a quasi-delict.
• Dyogi, et al. vs. Yatco, et al. — Mentioned for its ruling that "physical injuries" in Article 33 includes homicide. However, the Court distinguished it by clarifying that the charge against Paje was for the offense of reckless imprudence, which is not covered by Article 33, regardless of its result.

• Article 33, Civil Code — The Court determined that this article, which allows for an independent civil action for defamation, fraud, and physical injuries, was not applicable because the charge of reckless imprudence is not one of the enumerated offenses.
• Article 1146, Civil Code — This article establishes a four-year prescriptive period for actions based on quasi-delict. The Court applied this to rule that the plaintiffs' civil action, if considered as one based on quasi-delict, was filed out of time.
• Rule 111, Section 3, Rules of Court (Former) — Cited to support the ruling that the extinction of a criminal action by acquittal on the ground that the act did not exist also extinguishes the corresponding civil action for damages.
• Article 365, Revised Penal Code — Referenced in relation to the nature of criminal negligence, establishing that the offense is the negligent act itself, which is distinct from its consequences.