Manliclic v.

Calaunan

FACTS: Petitioner Manliclic is a driver of Philippine Rabbit Bus Lines, Inc. (PRBLI) While driving his bus
going to Manila, he bumped rear left side of the owner-type jeep of Respondent Calaunan. Because of
the collision, petitioner was criminally charged with reckless imprudence resulting to damage to
property with physical injuries. Subsequently, respondent filed a damage suit against petitioner and
PRBLI.

According to respondent, his jeep was cruising at the speed of 60 to 70 kilometers per hour on the slow
lane of the expressway when the Philippine Rabbit Bus overtook the jeep and in the process of
overtaking the jeep, the Philippine Rabbit Bus hit the rear of the jeep on the left side. At the time the
Philippine Rabbit Bus hit the jeep, it was about to overtake the jeep. In other words, the Philippine
Rabbit Bus was still at the back of the jeep when the jeep was hit. On the other hand, according to
petitioner, explained that when the Philippine Rabbit bus was about to go to the left lane to overtake
the jeep, the latter jeep swerved to the left because it was to overtake another jeep in front of it.

Petitioner was then acquitted of the criminal charges against him. However, in th civil case, he, along
with his employer, PRBLI, was still made to pay damages to respondent.

ISSUE: What is the effect of Manliclic’s acquittal to the civil case?

RULING:
SINCE THE CIVIL CASE IS ONE FOR QUASI DELICT, MANLICLIC’S ACQUITTAL DOES NOT AFFECT THE CASE.
MANLICLIC AND PRBLI ARE STILL LIABLE FOR DAMAGES.
A quasi-delict or culpa aquiliana is a separate legal institution under the Civil Code with a substantivity
all its own, and individuality that is entirely apart and independent from a delict or crime – a distinction
exists between the civil liabilityarising from a crime and the responsibility for quasi-delicts or culpa
extracontractual. The same negligence causing damages may produce civil liability arisingfrom a crime
under the Penal Code, or create an action for quasi-delicts or culpa extra-contractual under the Civil
Code.It is now settled that acquittal of the accused, even if based on a finding that he is not guilty, does
not carry with it the extinction of the civil liability based on quasi delict.

In other words, if an accused is acquitted based on reasonable doubt on his guilt, his civil liability arising
from the crime may be proved by preponderance of evidence only. However, if an accused is acquitted
on the basis that he was not the author of the act or omission complained of said acquittal closes the
door to civil liability based on the crime or ex delicto.

SPOUSES FRANCO Vs. IAC

FACTS: The instant petition deals mainly with the nature of an employer's liability for his employee's
negligent act.
At about 7:30 in the evening of October 18, 1974, Macario Yuro swerved the northbound Franco
Bus_with Plate No. XY320-PUB he was driving to the left to avoid hitting a truck with a trailer parked
facing north along the cemented pavement of the MacArthur Highway at Barrio Talaga, Capas Tarlac,
thereby taking the lane of an incoming Isuzu Mini Bus bearing Plate No. YL- 735 being driven by one
Magdaleno Lugue and making a collision between the two (2) vehicles an unavoidable and disastrous
eventuality.

Dragged fifteen (15) meters from the point of impact (midway the length of the parked truck with
trailer), the mini bus landed right side down facing south in the canal of the highway, a total wreck. The
Franco Bus was also damaged but not as severely. The collision resulted in the deaths of the two (2)
drivers, Macario Yuro and Magdaleno Lugue, and two (2) passengers of the mini bus, Romeo Bue and
Fernando Chuay.

Consequently, Antonio Reyes, the registered owner of the Isuzu Mini Bus, Mrs. Susan Chuay, the wife of
victim Fernando Chuay, and Mrs. Lolita Lugue, the wife of driver-victim Magdaleno Lugue, filed an action
for damages through reckless imprudence against Mr. & Mrs. Federico Franco, the owners and
operators of the Franco Transportation Company

ISSUE: Whether the action for recovery of damages instituted by herein private respondents was
predicated upon crime or quasi delict.

RULING: YES, under Articles 2176 and 2180 of the Civil Code, liability is based on culpa aquiliana which
holds the employer primarily liable for tortious acts of its employees subject, however, to the defense
that the former exercised all the diligence of a good father of a family in the selection and supervision of
his emplovees,

Having thus established that Civil Case No. 2154 is a civil action to impose the primary liability of the
employer as a result of the tortious act of its alleged reckless driver, we confront ourselves with the
plausibility of defendants-petitioners' defense that they observed due diligence of a good father of a
family in the selection and supervision of their employees. On this point, the appellate court has
unequivocally spoken in affirmation of the lower court's findings, to wit:

"Anyway, a perusal of the record shows that the appellants were not able to establish the defense of a
good father of a family in the supervision of their bus driver.

Consequently, therefore, we find petitioners liable for the damages claimed pursuant to their primary
liability under the Civil Code.

CEREZOV.TUAZON

FACTS: A Country Bus Lines passenger bus, driven by Danilo Foronda and owned by Mrs. Cerezo, collided
with a tricycle, driven by Tuazon, along Captain M. Palo Street, Sta. Ines, Mabalacat,Pampanga.Because
of this,Tuazon suffered serious physical injuries, making him unable to walk and disabled,with his thumb
and middle finger on the left hand being cut.

Tuazon filed a complaint for damages against: (1) Mrs. Cerezo;(2)AttorneyJuan Cerezo (husband of
Mrs.Cerezo); (3) Foronda. Tuazon alleged that at the time of the incident, Tuazon was in his proper lane,
while Foronda willfully, unlawfully, and feloniously operate the said motor vehicle in a negligent,
careless, and imprudent manner without due regard to traffic rules and regulations, there being a “Slow
Down”sign near the scene of the incident

On May 30, 1995, the RTC ruled in favor of Tuazon, made no pronouncement on Foronda’s
liability since no summons was served on him, and held Mrs. Cerezo solelyliable due to the
negligence of Mrs. Cerezo’s employee.

ISSUE: W/N it is required for the RTC to acquire jurisdiction over Foronda first, before Mrs.
Cerezo, as Foronda’s employer, could be held liable for the damages due to Foronda’s
negligence.
RULING: NO.Foronda is not an indispensable party to the case.
A negligent act may produce civil liability arising from a delict under Article 103 of the RPC, or
an action for a quasi- delict under Article 2180 of the Civil Code. An action based on a quasi-
delict may proceed independently from the criminal action. In this case, Tuazon chose to file an
action for damages based on a quasi-delict and RTC found Mrs. Cerezo, as
Foronda’semployer,vicariously liable undernArticle 2180 for Foronda’s negligence.