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RUBEN MANIAGO v. CA

FACTS:

Petitioner Ruben Maniago owned shuttle buses used to transport employees of Texas Instruments, (Phils.), Inc. from Baguio City to its plant site. On January 7, 1990, one of Maniago's buses was involved in a vehicular accident with a passenger jeepney owned by private respondent Alfredo Boado along Loakan Road in Baguio City. A criminal case for reckless imprudence resulting in damage to property and multiple physical injuries was filed against Maniago's driver, Herminio Andaya. A civil case for damages was also filed by Boado against Maniago. Petitioner moved for the suspension of the civil case, but the trial court denied the motion, ruling that the civil action could proceed independently of the criminal action. Petitioner filed a petition for certiorari and prohibition with the Court of Appeals, which dismissed the petition. This led to the present petition for review on certiorari. The central issue is whether a civil action for damages may proceed independently of a criminal case without the need for reservation.

ISSUES:

  1. Whether, in the absence of a reservation to bring a separate civil action for damages, a private respondent may proceed with such a civil action independently of the criminal case against the petitioner's driver.

RULING:

  1. The Supreme Court ruled that the private respondent cannot proceed with the civil action for damages independently of the criminal case without having reserved the right to file it separately in accordance with Rule 111, Section 1 of the Revised Rules of Criminal Procedure. Consequently, since no such reservation was made, the civil action is deemed to have been instituted with the criminal action, and its dismissal follows the dismissal of the criminal case.

PRINCIPLES:

  1. A civil action for the recovery of civil liability is impliedly instituted with the criminal action unless:

    • The offended party waives the civil action,

    • Reserves their right to institute it separately, or

    • Institutes the civil action prior to the criminal action.

  2. A civil action under Articles 32, 33, 34, and 2176 of the Civil Code arising from the same act or omission as that of the accused may be brought separately, provided the right to bring it has been reserved.

  3. The requirement to reserve the right to file separate civil actions is procedural in nature and serves the general interest of orderly procedure.

  4. The acquittal of the accused in a criminal case does not necessarily preclude a separate civil action unless the acquittal explicitly states that the acts from which the civil liability might arise did not occur.

  5. The right to institute separate actions under the Civil Code for damages must be reserved; otherwise, the right is deemed waived, and the action is assumed to accompany the criminal case.

  6. Practical and policy considerations against double recovery enforce the requirement to reserve separate civil actions to prevent multiple recoveries for the same act or omission.