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RULING:
The Supreme Court held that the acquittal of the bus driver was
based on reasonable doubt, which means that the civil case for
FACTS:
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
with the Philippine Rabbit Bus driven by Angelo Cuevas and wth a
finding that he was not guilty but only on reasonable doubt. Thus, it
which the civil might arise did not exist. Thus, the civil liability is not
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
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
extinguishment of his civil liability, since his civil liability aroused from
who thereby incur only civil liability; and, where the civil liability does
claiming that the civil case should pursue. This was then appealed to
not arise from or is not based upon the criminal act of which the
ISSUE:
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 victims heirs. The case was remanded to the trial court to
determine the civil liability of the accused.
MANANTAN VS CA
Ruling: NO. Our law recognizes two kinds of acquittal, with different
ground that the accused is not the author of the act or omission
liability, for a person who has been found not to be the perpetrator of
any act or omission cannot and can never be held liable for such act
operated the same while along the Daang Maharlika of the said
question, and the civil action, if any, which will be instituted must be
based on ground other than the delict complained of. The second
accused. In this case, even if the guilt of the accused has not been
spouses Nicolas filed their notice of appeal on the civil aspect of the
decision of the trial court did not state in clear and equivocal terms
trial courts judgment. The Nicolas spouses prayed that the decision
liability, the court a quo noted that at the time the accident occurred,
Appeals finding that the defendant is civilly liable for his negligent
and reckless act of driving his car which was the proximate cause of
Nicolas.
February 1971, dismissing the complaint for damages, and the order
dated
27
March
1971
denying
the
petitioners'
motion
for
action.
RULING:
After trial on the merits, the court acquitted the accused for failure of
guilt has not been proved beyond reasonable doubt. Civil action for
damages against the same accused for the death of Bonite, with the
Court of First Instance of Misamis Occidental, 16th Judicial District,
In the case at bar, the criminal case for Homicide through Reckless
Branch III. The court a quo dismissed the complaint for damages on
25 February 1971. In its ruling, the court held that since the plaintiffs
did not reserve the right to file and independent civil action, and the
damages
The court held that the petitioners may also base such separate civil
Penal Code punishes the negligent or reckless act, not the result
action for damages on Article 2176 of the Civil Code. Acquital of the
determine
the recovery of civil liability, arising not from criminal negligence, but
from quasi-delict or culpa aquiliana. It has been held that Article 2176
The court a quo's ruling that the petitioners did not reserve the right
action. It allows an action for damages against the accused upon the
Article 29 of the Civil Code does not state that the right to file an
availed of only in offenses not arising from a tortious act. The only
which does not require such a reservation. This provision has been
requisite to file a civil action from damages is that the accused must
doubt. When the law does not distinguish, the court should not
distinguish.
The Orders dated 25 February 1971 and 27 March 1971 of the court
a quo was reversed and set aside, and a new one is entered
reinstating the action for recovery of damages by the petitioners and
directing the said court to proceed trial with the case.