Yumul v. Juliano
REITERATIONFacts
The Antecedents: Irineo Yumul filed a civil action to recover damages arising from the death of his daughter, Teresita Yumul, who was struck by a truck owned by Pampanga Bus Co. (Pambusco) and driven by Antonio Juliano. Antonio Juliano was previously convicted of homicide through reckless imprudence under section 67(d) of Act No. 3992. The private prosecution reserved its right to file a separate civil action. Procedural History: Irineo Yumul, later joined by the adopted father of the deceased, Conrado Miranda, filed the present action against Antonio Juliano and Pambusco. Antonio Juliano was declared in default. The Court of First Instance of Pampanga sentenced Juliano to pay P2,000 in damages but absolved Pambusco, finding that it exercised the diligence of a good father of a family under article 1903 of the Civil Code. The Petition: The case was elevated to the Supreme Court on a question of law: whether the lower court erred in applying article 1903 of the Civil Code instead of the Penal Code for civil liability arising from a penal act.
Issue(s)
Whether the civil liability arising from a criminal act should be governed by the Penal Code or the Civil Code. Whether the employer (Pampanga Bus Co.) is subsidiary liable for the damages caused by its employee (Antonio Juliano) despite exercising diligence of a good father of a family.
Ruling
The judgment of the lower court is modified. The Pampanga Bus Co. is adjudged to be subsidiary liable to the plaintiff-appellant for civil damages in the sum of P2,000, in the event that its codefendant, Antonio Juliano, is insolvent or unable to satisfy the judgment.
Ratio Decidendi
On the governing law for civil liability arising from crimes: The Court held that civil obligations arising from crimes or misdemeanors are expressly governed by the provisions of the Penal Code, as provided in Article 1092 of the Civil Code. Therefore, the lower court erred in applying Article 1903 of the Civil Code, which pertains to civil liability arising from wrongful or negligent acts not punishable by law. The Court emphasized that any ruling permitting a master to escape liability by merely proving diligence in selection and training would undermine the purpose of holding employers accountable for the acts of their employees in the course of employment. On the subsidiary liability of the employer: The Court found the Pampanga Bus Co. subsidiary liable under Articles 102 and 103 of the Revised Penal Code. It was admitted that Antonio Juliano was an employee and chauffeur of the company. The records, including the information filed and the sentence in the criminal case, conclusively showed that Juliano operated the truck in a reckless, imprudent, and negligent manner. Consequently, the employer's defense of exercising all the diligence of a good father of a family in the employment and training of its chauffeur was rendered irrelevant for the purpose of avoiding subsidiary liability under the Penal Code. The Court noted that this subsidiary liability applies to employers for felonies committed by their servants, pupils, workmen, apprentices, or employees in the discharge of their duties.
Main Doctrine
Civil obligations arising from crimes or misdemeanors are governed by the Penal Code, and the subsidiary civil liability of employers for felonies committed by their employees in the discharge of their duties is established under Articles 102 and 103 of the Revised Penal Code, irrespective of the employer's diligence in selecting and training the employee.