Case Title: Gerry S. Fegarido and Linalie A. Milan, Petitioners, vs. Almarina S. Alcantara, Cynthia A.

De Vera,
Yolanda A. Tayag, Cristy Susan A. De Guzman, Jessie S. Alcantara, Emilie A. Velancio, Judith A. Raguïngan,
Charlie S. Alcantara, all suing as heirs of their deceased mother Cristina S. Alcantara (victim), and all
represented by their attorney-in-fact and co-plaintiff, Charlie S. Alcantara, Respondents.
G.R. No.: 240066

Date: June 13, 2022

Doctrine: In negligence cases, the aggrieved party may file an independent civil action for damages based
on quasi-delict separately from a criminal action for imprudence. This civil action may proceed
simultaneously with the Criminal action and requires only preponderance of evidence. Nevertheless, the
aggrieved party may recover damages only once based on the same act or omission.

Facts:

 On October 15, 2008, Cristina S. Alcantara was hit by a public utility jeepney driven by Gerry S.
Fegarido while she was crossing the road in Olongapo City. She sustained fatal injuries and died
three days later.
 Fegarido was charged with reckless imprudence resulting in homicide but was acquitted due to
insufficient evidence to prove his guilt beyond a reasonable doubt.
 The heirs of Cristina S. Alcantara filed a civil action for damages against Fegarido and Linalie A.
Milan, the registered owner of the jeepney.
 The Regional Trial Court found Fegarido and Milan solidarily liable for damages, which was affirmed
by the Court of Appeals.

Issues:
Whether Fegarido can be held liable for negligence despite his acquittal in the criminal case.
Whether Milan can be held vicariously liable for Fegarido's negligence.
Whether the damages awarded by the lower courts are proper.

Ruling:
 Fegarido can still be held civilly liable for negligence despite his acquittal in the criminal case. The
civil action for damages based on quasi-delict is separate from the criminal action and requires only
preponderance of evidence.
 Milan can be held vicariously liable for Fegarido's negligence as the registered owner of the jeepney
since she failed to exercise due diligence in selecting and supervising her employee.
 The damages awarded by the lower courts, including actual damages, moral damages, exemplary
damages, and attorney's fees and litigation expenses, are affirmed.
Legal Principles:
 In negligence cases, the aggrieved party may file an independent civil action for damages based on
quasi-delict (Art.2177) separately from a criminal action for imprudence (Art 100 RPC). This civil
action may proceed simultaneously with the Criminal action and requires only preponderance of
evidence.
 Employers shall be liable for the damages caused by their employees acting within the scope of
their assigned tasks. Once negligence on the part of the employee is established, a presumption
arises that the employer was negligent in the selection and/or supervision of said employee. (Art.
2180 Civil Code of the Philippines)
 Actual damages are compensation for an injury that will put the injured party in the position where
it was before the injury. Moral damages are awarded to compensate the claimant for actual injury
caused by the defendant's culpable action. Exemplary damages are awarded as a means of molding
behavior that has socially deleterious consequences, serving as an example or warning for the
public good. (Art. 2199, 2200. 2201)
Conclusion:
 The petition filed by Gerry S. Fegarido and Linalie A. Milan is denied. The decision of the Court of
Appeals affirming their solidary liability for damages to the heirs of Cristina S. Alcantara is upheld.
Fegarido and Milan are ordered to pay the awarded damages as specified by the lower courts.

Notes:

Article 2176 of the Civil Code of the Philippines defines quasi-delicts as follows: "Whoever by act or omission causes damage to
another, there being fault or negligence, is obliged to pay for the damage done. Such fault or negligence, if there is no pre-
existing contractual relation between the parties, is called a quasi-delict and is governed by the provisions of this Chapter."

Article 2177 of the Civil Code of the Philippines states: "Responsibility for fault or negligence under the preceding article is
entirely separate and distinct from the civil liability arising from negligence under the Penal Code. But the plaintiff cannot recover
damages twice for the same act or omission of the defendant."

Article 218O Civil Code of the Philippines states: The obligation imposed by Article 2176 is demandable not only for one's own
acts or omissions, but also for those of persons for whom one is responsible.

Article 2199 Civil Code of the Philippines: "Except as provided by law or by stipulation, one is entitled to an adequate
compensation only for such pecuniary loss suffered by him as he has duly proved. Such compensation is referred to as actual or
compensatory damages."

Article 2200 Civil Code of the Philippines: "Indemnification for damages shall comprehend not only the value of the loss suffered
but also that of the profits which the obligee failed to obtain."

Article 2201 Civil Code of the Philippines: "In contracts and quasi-contracts, the damages for which the obligor who acted in
good faith is liable shall be those that are the natural and probable consequences of the breach of the obligation, and which the
parties have foreseen or could have reasonably foreseen at the time the obligation was constituted."