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PHILIPPINE RABBIT BUS LINES v. PEOPLE

FACTS:

The case involves a petition for review assailing the resolutions of the Court of Appeals (CA) dismissing the appeal of the petitioner, an employer, from the judgment of the Regional Trial Court (RTC) convicting the accused-employee of reckless imprudence resulting to triple homicide, multiple physical injuries, and damage to property. In the criminal case, the accused-employee was sentenced to a certain penalty and ordered to pay damages to the victims and their heirs. The judgment of conviction and the award of civil liability became final and executory after the accused-employee jumped bail and remained at large. Subsequently, the petitioner (employer) filed a notice of appeal on its own behalf seeking a review of its subsidiary civil liability. The CA ruled that the employer cannot independently appeal the judgment of conviction and the fixed civil liability as it would nullify a final judgment. The employer's subsidiary liability is included in the judgment against the employee. Hence, this petition.

ISSUES:

  1. Propriety of appeal by the employer.

  2. Finality of a decision in a criminal case.

  3. Whether the civil liability of the accused arising from the crime charged is deemed impliedly instituted in a criminal action.

  4. Whether the right to bring civil actions based on the Civil Code needs to be reserved in the criminal prosecution.

  5. Whether the institution or waiver of the right to file a separate civil action arising from the crime charged extinguishes the right to bring such action.

  6. Whether an employer, as a party to the criminal case, is accorded the right to pursue the case including the appeal.

  7. Can an accused waive his right to appeal by fleeing after the case has been submitted for decision?

  8. Does an employer's subsidiary liability accrue upon the finality of the judgment against the accused-employee?

  9. Whether the employer's subsidiary liability is dependent upon the employee's criminal negligence.

  10. Whether the requirements for filing an appeal should be strictly complied with.

  11. Whether the petitioner employer was deprived of due process.

RULING:

  1. The employer's appeal does not stay the finality of the judgment of conviction against the accused-employee who jumped bail. The appellate court may, upon motion or motu proprio, dismiss the appeal if the appellant escapes from prison, jumps bail, or flees to a foreign country during the pendency of the appeal. The accused loses their standing in court when they abscond, and unless they surrender or submit to the court's jurisdiction, they are deemed to have waived their right to seek judicial relief.

  2. The judgment against the accused-employee has become final and executory since he escaped and refused to surrender to the proper authorities. A judgment of conviction becomes final after the lapse of the period for perfecting an appeal, when the sentence has been partially or totally satisfied or served, when the accused has waived in writing his right to appeal, or has applied for probation.

  3. Yes, the civil liability of the accused arising from the crime charged is deemed impliedly instituted in a criminal action, unless the offended party waives the civil action, reserves the right to institute it separately, or institutes it prior to the criminal action.

  4. No, the right to bring civil actions based on the Civil Code does not need to be reserved in the criminal prosecution, as these actions remain separate, distinct, and independent of any criminal prosecution based on the same act.

  5. No, the institution or waiver of the right to file a separate civil action arising from the crime charged does not extinguish the right to bring such action.

  6. No, an employer is not considered a direct party to the criminal case filed against the employee, and therefore does not have the right to pursue the case including the appeal.

  7. Yes, an accused can waive his right to appeal by fleeing after the case has been submitted for decision. By fleeing, the accused exhibits contempt of the authority of the court and places himself in a position to speculate on his chances for a reversal. Such conduct is intolerable and does not invite leniency on the part of the appellate court. Consequently, the judgment against an appellant who escapes and refuses to surrender to the proper authorities becomes final and executory.

  8. Yes, an employer's subsidiary liability accrues upon the finality of the judgment against the accused-employee. The liability of an employer in a finding of guilt against its accused-employee is subsidiary. Under Article 103 of the Revised Penal Code, employers are subsidiarily liable for the adjudicated civil liabilities of their employees in the event of the latter's insolvency. The judgment of conviction should bind the person who is subsidiarily liable. The employer's subsidiary liability is incidental to and dependent on the pecuniary civil liability of the accused-employee. Therefore, once the civil liability of the accused-employee has become final and enforceable, the employer's subsidiary liability also becomes immediately enforceable.

  9. Yes, the employer's subsidiary liability is dependent upon the employee's criminal negligence. The employer becomes subsidiarily liable upon the conviction of the employee and upon proof of the latter's insolvency.

  10. Yes, the requirements for filing an appeal should be strictly complied with. The right to appeal is a procedural remedy that may be exercised only in the manner prescribed by the provisions of law authorizing such exercise. Deviations from the rules on appeal cannot be tolerated.

  11. No, the petitioner employer was not deprived of due process. It participated in the proceedings before the Regional Trial Court (RTC), although it lost its right to appeal due to the accused-employee's act of jumping bail.

PRINCIPLES:

  • Both the accused and the prosecution may appeal a criminal case, but the government may do so only if the accused would not thereby be placed in double jeopardy. The prosecution cannot appeal on the ground that the accused should have been given a more severe penalty.

  • The appellate court may dismiss an appeal during its pendency if the accused jumps bail.

  • The accused cannot be accorded the right to appeal unless they voluntarily submit to the jurisdiction of the court or are otherwise arrested within 15 days from notice of the judgment against them.

  • A judgment of conviction attains finality when certain conditions are met, such as the lapse of the period for perfecting an appeal, satisfaction or service of the sentence, waiver of the right to appeal, or application for probation.

  • Employers may be held subsidiary liable for felonies committed by their employees in the discharge of their duties.

  • Civil actions for the recovery of civil liability arising from the offense charged are deemed instituted in a criminal prosecution.

  • The civil liability of the accused arising from the crime charged is deemed impliedly instituted in a criminal action, unless waived, reserved, or instituted separately.

  • Civil actions based on the Civil Code are separate, distinct, and independent from any criminal prosecution based on the same act, and do not need to be reserved in the criminal prosecution.

  • The institution or waiver of the right to file a separate civil action arising from the crime charged does not extinguish the right to bring such action.

  • Employers, although having an interest in criminal cases filed against their employees, are not considered parties to the criminal cases and cannot pursue the case including the appeal.

  • The right to appeal an unfavorable sentence in a criminal case implies a waiver of the constitutional safeguard against double jeopardy, and the appellate court may modify the judgment, including imposing a higher penalty.

  • Absconding by the accused implies a waiver of the right to appeal and makes the judgment of the court below final and executory.

  • An accused can waive his right to appeal by fleeing after the case has been submitted for decision.

  • An employer's subsidiary liability accrues upon the finality of the judgment against the accused-employee.

  • The liability of an employer in a finding of guilt against its accused-employee is subsidiary.

  • The judgment of conviction binds the employer with regard to both the criminal and civil liability of the accused-employee.

  • The employer's subsidiary liability is dependent on the pecuniary civil liability of the accused-employee.

  • The employer's subsidiary liability can be enforced in the same criminal action in which the employee's liability has been pronounced.

  • The employer's subsidiary liability is dependent upon the employee's criminal negligence and upon proof of the latter's insolvency.

  • The requirements for filing an appeal must be strictly complied with.

  • The right to appeal is not a natural right or part of due process, but a procedural remedy of statutory origin.

  • Deviations from the rules on appeal cannot be tolerated.

  • The losing party's right to file an appeal within the prescribed period entitles the winning party to enjoy the finality of the resolution of the case.

  • Participating in the proceedings before the court does not necessarily mean that due process was denied.

  • Execution of the court decision can only be enforced against the accused after proof of his insolvency.