CASUPANA

N VS.
LAROYA
Psyche Shyne P.
Ostique
Title: Casupanan vs. Laroya

Case: G.R. No. 145391

Ponente: CARPIO, J

Decision Date:Aug 26, 2002

 FACTS
• Mario Llavore Laroya and Roberto
Capitulo were involved in a vehicular
accident.
• Laroya filed a criminal case against
Avelino Casupanan, the driver of
Capitulo's vehicle, for reckless imprudence
resulting in damage to property.
 FACTS
• Casupanan and Capitulo, on the other hand,
filed a civil case against Laroya for quasi-
delict.
• The civil case was dismissed by the Municipal
Circuit Trial Court (MCTC) on the ground of
forum-shopping.
 ISSUE
• Can an accused in a pending criminal case for
reckless imprudence file a separate civil
action for quasi-delict against the private
complainant in the criminal case?
 RULING
• The dismissal of the civil case by the MCTC
was without prejudice, as there was no
declaration that the dismissal was with
prejudice.
• Therefore, the dismissal was not appealable,
and the proper remedy was a special civil
action under Rule 65.
 RULING
• There was no forum-shopping in this case because
separate civil actions can be filed independently of
criminal actions.
• The accused can file a civil action for quasi-delict for
the same act or omission he is accused of in the
criminal case, as expressly allowed in the rules.
• The court granted the petition and reinstated the civil
case, ruling that the dismissal of the civil case by the
MCTC was erroneous.
Thank you