Libi v.

Intermediate Appellate Court

G.R. No. 70890,18 September 1992

FACTS:

Julie Ann Gotiong and Wendell Libi were sweethearts until the former broke up with the latter after
she found out the Wendell were irresponsible and sadistic. Wendell wanted reconciliation but was
not granted by Julie so it prompted him to resort to threats. One day, they were found dead from a
single gunshot wound each coming from the same gun. The parents of Julie herein private
respondents filed a civil case against the parents of Wendell to recover damages. Trial court
dismissed the complaint for insufficiency of evidence but was set aside by CA.

ISSUE:

Whether the parents should be held liable for such damages.

RULING:

Yes. The parents are and should be held primarily liable for the civil liability arising from criminal
offenses committed by their minor children under their legal authority or control, or who live in their
company, unless it is proven that the former acted with the diligence of a good father of a family to
prevent such damages.

Under the Family Code, this civil liability is now, without such alternative qualification, the
responsibility of the parents and those who exercise parental authority over the minor offender. For
civil liability arising from quasi-delicts committed by minors, the same rules shall apply in accordance
with Articles 2180 and 2182 of the Civil Code, as so modified.

Since the parents failed to establish in its defense, the exercise of the diligence of a good father of a
family to prevent such damage, the court held that the civil liability of the parents for quasi-delict of
their minor children is primary and not subsidiary.