FACTS:

Antonio Daluraya was charged with Reckless Imprudence Resulting in Homicide in connection with the death of Marina Oliva. The incident occurred when Marina Oliva was hit by a Nissan Vanette while crossing the street. She was rushed to the hospital but eventually died. The prosecution presented several witnesses, including an eye-witness to the incident, a family member of the victim, a doctor who conducted the autopsy, and a police investigator. After the prosecution rested its case, Daluraya filed a demurrer, asserting that he was not positively identified as the driver of the vehicle and that there was insufficient evidence on how the incident transpired. The Metropolitan Trial Court (MeTC) granted Daluraya's demurrer and dismissed the case for insufficiency of evidence. The MeTC found that none of the prosecution witnesses sufficiently established that Daluraya committed the crime. The MeTC also denied the civil aspect of the case. Marla, the daughter of the victim, appealed to the Regional Trial Court (RTC), insisting on Daluraya's civil liability. The RTC dismissed the appeal and affirmed the MeTC's ruling. Marla then appealed to the Court of Appeals (CA), which granted the petition and found Daluraya civilly liable for the victim's death. The CA considered various pieces of evidence to support its finding, including a sworn statement by Daluraya, the testimony of an eye-witness, and a referral letter from the police. Daluraya filed a motion for reconsideration, which the CA denied. The issue before the Court is whether or not the CA was correct in finding Daluraya civilly liable despite his acquittal in the criminal case for Reckless Imprudence Resulting in Homicide.

ISSUES:

1. Whether or not the Court of Appeals was correct in finding Daluraya civilly liable for Marina Oliva's death despite his acquittal in the criminal case for Reckless Imprudence Resulting in Homicide on the ground of insufficiency of evidence.

RULING:

1. The Court ruled in favor of the petitioner, Antonio L. Daluraya. The Court held that Daluraya cannot be held civilly liable for Marina Oliva's death since he was acquitted in the criminal case for Reckless Imprudence Resulting in Homicide due to insufficiency of evidence. The Court emphasized that civil liability is merely derived from the criminal offense and that any civil liability cannot exist where the criminal act itself has not been proven. Moreover, the Court found that there was no clear and competent evidence to establish Daluraya's guilt beyond reasonable doubt. Therefore, the Court reversed the decision of the Court of Appeals and dismissed the civil liability imposed on Daluraya.

PRINCIPLES:

• Civil liability is merely derived from the criminal offense and cannot exist where the criminal act itself has not been proven.

• Acquittal in a criminal case on the ground of insufficiency of evidence precludes holding the accused civilly liable for the same act.