Corpus v. Paje
REITERATIONFacts
The Antecedents: On December 23, 1956, a passenger bus driven by Felardo Paje collided with a jeep driven by Clemente Marcia, resulting in Marcia's death and physical injuries to two other persons. A criminal information for homicide and double serious physical injuries through reckless imprudence was filed against Paje. The heirs of Clemente Marcia reserved their right to institute a separate civil action for damages. Procedural History: Felardo Paje was convicted in the Court of First Instance of Pampanga. While his appeal was pending before the Court of Appeals, Clemente Marcia's heirs filed a separate civil action for damages against Paje and Victory Liner Transportation Co., Inc. On November 21, 1961, the Court of Appeals reversed the conviction and acquitted Paje, finding the collision to be a case of pure accident and not due to reckless imprudence. Subsequently, the defendants in the civil case moved to dismiss, arguing that the acquittal barred the civil action. The motion was denied. At pre-trial, the defendants raised the defense of prescription, arguing that the action, if based on quasi-delict, was filed beyond the four-year prescriptive period. The Court of First Instance of Rizal dismissed the complaint on this ground. The Petition: The plaintiffs-appellants appealed the dismissal order to the Supreme Court, contending that the lower court erred in dismissing the complaint.
Issue(s)
Whether the acquittal of the defendant in the criminal case for reckless imprudence bars the civil action for damages based on the same act. Whether the civil action, if considered as based on quasi-delict, had prescribed.
Ruling
The Supreme Court affirmed the order of the Court of First Instance of Rizal dismissing the complaint.
Ratio Decidendi
On the issue of acquittal barring the civil action: The Court held that the acquittal of Felardo Paje by the Court of Appeals in the criminal action, on the ground that the reckless imprudence charged did not exist and the collision was a case of pure accident, served as a bar to the civil action for damages. This is because criminal negligence, or reckless imprudence, is not one of the three crimes enumerated in Article 33 of the Civil Code (defamation, fraud, and physical injuries) which authorize the institution of an independent civil action. Although the term "physical injuries" in Article 33 has been held to include homicide, the charge against Paje was for "reckless imprudence resulting in homicide," not for homicide itself. The offense of criminal negligence lies in the negligent or careless act, not the result. Therefore, as reckless imprudence is not listed in Article 33, there is no independent civil action that can be instituted in connection with said offense. The general rule applies: the acquittal of the defendant in the criminal action extinguishes civil liability based upon the same criminal act, as provided in Rule 111, Section 3 of the Rules of Court, which states that the extinction of the criminal action by acquittal on the ground that the criminal act did not exist necessarily extinguishes the civil action based upon the same act. On the issue of prescription: Assuming, arguendo, that the civil action for damages was based upon a quasi-delict, the Court found the trial court's ruling that the action had prescribed to be correct. An action upon a quasi-delict must be instituted within four (4) years from the commission of the act, as provided by Article 1146 of the Civil Code. The prescriptive period began to run from December 23, 1956, the date of the collision. The Court further clarified that the running of this prescriptive period was not interrupted by the institution of the criminal action for reckless imprudence, citing the case of Paulan vs. Sarabia.
Main Doctrine
The acquittal of an accused in a criminal case for reckless imprudence, on the ground that the act did not exist or was a case of pure accident, bars a subsequent civil action for damages based on the same criminal act, as reckless imprudence is not among the offenses for which an independent civil action may be filed under Article 33 of the Civil Code. Furthermore, if the civil action were to be based on quasi-delict, it must be filed within the prescriptive period of four years from the commission of the act.