Marcia vs. Court of Appeals

An acquittal of an accused in a criminal case for reckless imprudence, which is based on a final judicial declaration that the fact from which civil liability may arise did not exist, bars a subsequent civil action for damages arising from the same incident.

The case originated from a vehicular collision on December 23, 1956, in Lubao, Pampanga, between a passenger bus operated by Victory Liner, Inc. and driven by Felardo Paje, and a jeep driven by Clemente Marcia. The collision resulted in the death of Clemente Marcia and physical injuries to the petitioners, Edgar Marcia and Renato Yap, who were passengers in the jeep. This led to the filing of both a criminal action against the bus driver and a separate civil action for damages by the injured parties against the driver and the bus company.

• On December 23, 1956, a Victory Liner bus driven by respondent Felardo Paje collided with a jeep driven by Clemente Marcia in Lubao, Pampanga.
• The collision caused the death of Clemente Marcia and physical injuries to petitioners Edgar Marcia and Renato Yap.
• A criminal case for homicide and serious physical injuries thru reckless imprudence was filed against Paje.
• Petitioners also filed a separate civil action for damages against Paje and Victory Liner, Inc., alleging that the mishap was due to Paje's reckless imprudence and negligence.
• Paje was initially convicted by the CFI of Pampanga but was later acquitted by the Court of Appeals.
• The Court of Appeals, in acquitting Paje, found that he was not speeding, was diligent, and that the jeep driver was running at a fast pace, lost control, and crashed into the bus which had already pulled over to the shoulder.
• The Court of Appeals concluded in the criminal case that "CRIMINAL NEGLIGENCE is WANTING" and that Paje was "NOT even guilty of CIVIL NEGLIGENCE," deeming the event a "case of PURE ACCIDENT."
• Following this acquittal, the CFI of Rizal dismissed the petitioners' civil complaint, and this dismissal was affirmed by the Court of Appeals, prompting the present petition to the Supreme Court.

• The civil action for damages resulting from negligence is an independent civil action under Articles 33, 2176, and 2177 of the Civil Code and Section 2 of Rule 111 of the Rules of Court.
• The acquittal of respondent Felardo Paje in the criminal case is entirely irrelevant to the instant civil action.
• The statement by the Court of Appeals in the criminal case that Paje was not guilty of civil negligence was an extraneous and void statement made without jurisdiction.
• The evidence from the criminal action, including the decision of acquittal, is inadmissible in the civil action for damages.
• Petitioners established by a preponderance of evidence that they suffered damages as a proximate result of the negligence of respondent Paje.

• The acquittal of Felardo Paje by the Court of Appeals in the criminal case is a bar to the civil action.
• The Court of Appeals' decision in the criminal case contained a declaration that the fact from which the civil liability might arise did not exist, as it found the collision was a "pure accident" and Paje was not negligent.
• The case is governed by Section 3(c), Rule 111 of the Rules of Court, which states that extinction of the penal action carries with it the extinction of the civil action if the judgment declares that the fact from which the civil might arise did not exist.
• The Supreme Court's ruling in Corpus vs. Paje, a case involving the same accident and defendants, had already established that the acquittal barred a separate civil action for damages.

• Procedural Issues:
  • Whether the records of the criminal case, including the decision of acquittal, are admissible as evidence in the separate civil action for damages.
• Substantive Issues:
  • Whether the acquittal of the accused in a criminal case for reckless imprudence, based on a finding that the incident was a "pure accident" and that no negligence existed, bars a subsequent civil action for damages based on the same act.
  • Whether a civil action for damages arising from physical injuries caused by reckless imprudence is an independent civil action under Article 33 of the Civil Code.

• Procedural:
  • Yes, the evidence from the criminal case, specifically the decision of the Court of Appeals acquitting the accused, is relevant and material evidence in the civil case. Since the petitioners' cause of action is based on the alleged recklessness of the respondent driver, his acquittal and the court's declaration that the mishap was a "pure accident" are directly relevant. The lower court may even take judicial notice of such a decision.
• Substantive:
  • Yes, the acquittal bars the subsequent civil action. The Court held that under Section 3(c), Rule 111 of the Rules of Court, the extinction of the criminal action extinguishes the civil liability when the acquittal is based on a declaration that the fact from which the civil liability might arise did not exist. The finding by the Court of Appeals in the criminal case that Paje was not guilty of even civil negligence and that the collision was a "pure accident" is precisely such a declaration, thereby foreclosing any civil claim.
  • No, a civil action for physical injuries resulting from reckless imprudence is not the independent civil action contemplated by Article 33 of the Civil Code. The Court clarified that the "physical injuries" mentioned in Article 33 refer to those inflicted with malice or intent (deliberate acts), not those arising from criminal negligence. Therefore, petitioners cannot invoke Article 33 to proceed with their civil case independently of the result of the criminal action.

• Extinction of Civil Liability Arising from Crime — Under Section 3(c), Rule 111 of the Rules of Court, the extinction of a criminal action does not carry with it the extinction of the civil action, unless the acquittal proceeds from a declaration in a final judgment that the fact from which the civil liability might arise did not exist. In this case, the Court of Appeals' finding in the criminal case that the collision was a "pure accident" and that the driver was not guilty of any negligence was a declaration that the fact (negligence) from which civil liability could arise was non-existent, thus barring the civil action.
• Independent Civil Action under Article 33 — Article 33 of the Civil Code allows a civil action for damages arising from defamation, fraud, and physical injuries to proceed independently of the criminal prosecution. The Court ruled that physical injuries resulting from criminal negligence (a quasi-offense) are not included in the scope of "physical injuries" under this article, which contemplates injuries inflicted with malice. Thus, an independent civil action could not be instituted on this basis.

• "...CRIMINAL NEGLIGENCE is WANTING in this case, and that appellant was NOT even guilty of CIVIL NEGLIGENCE. Insofar as appellant was concerned, it was a case of PURE ACCIDENT."

• Corpus vs. Paje — Cited as controlling precedent. This case involved the same accident, driver, and company, but the plaintiffs were the heirs of the deceased jeep driver. The Supreme Court had previously ruled in that case that the acquittal of Paje on the ground that the collision was a pure accident barred the civil action for damages.
• Tan vs. Standard Vacuum Oil Company — Referenced to support the principle that an acquittal extinguishes civil liability if the court declares in its judgment that the fact from which civil liability might arise did not exist.
• De Mesa vs. Priela — Cited to reiterate the rule under the Rules of Court that the extinction of the penal action carries with it the extinction of the civil, if the acquittal is based on the non-existence of the fact from which the civil action could arise.
• People vs. Buan — Cited to define the nature of criminal negligence under Article 365 of the Revised Penal Code, explaining that the law penalizes the negligent or careless act itself, not the result.

• Rule 111, Section 3(c), Rules of Court — This was the primary rule applied by the Court to determine that the civil action was barred by the acquittal in the criminal case, as the acquittal was based on a finding that the fact from which civil liability might arise did not exist.
• Rule 111, Section 2, Rules of Court — This rule, invoked by the petitioners, allows for the institution of an independent civil action. The Court found it inapplicable because the conditions for its application were not met.
• Article 33, Civil Code — The Court ruled that the petitioners' case did not fall under this article because physical injuries resulting from reckless imprudence are not the "physical injuries" contemplated therein, which require malice.
• Articles 2176 and 2177, Civil Code — Although the basis for an action for quasi-delict, the Court's application of the rule on the preclusive effect of the findings in the criminal case (i.e., no negligence) meant that a separate action based on these articles could not succeed.