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Padua Vs Robles

This case discusses the civil liability arising from a negligent act that caused a vehicular accident. The driver, Romeo Punzalan, was criminally prosecuted and found guilty of homicide through reckless imprudence. The petitioners then filed a separate civil case against Punzalan and the vehicle owners to recover damages. The court affirmed that a negligent act gives rise to two separate liabilities - civil liability from the crime as well as liability from civil negligence. While the plaintiff cannot recover damages twice for the same act, the two liabilities can be pursued independently in separate cases.

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52 views2 pages

Padua Vs Robles

This case discusses the civil liability arising from a negligent act that caused a vehicular accident. The driver, Romeo Punzalan, was criminally prosecuted and found guilty of homicide through reckless imprudence. The petitioners then filed a separate civil case against Punzalan and the vehicle owners to recover damages. The court affirmed that a negligent act gives rise to two separate liabilities - civil liability from the crime as well as liability from civil negligence. While the plaintiff cannot recover damages twice for the same act, the two liabilities can be pursued independently in separate cases.

Uploaded by

sunsetsailor85
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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39. Bernabe Castillo, et al. vs. The Honorable Court of Appeals, et al.

, 176 SCRA 591


a!ts" This is a petition for revie# on !ertiorari #here petitioners see$ for the
rene#al of the Court of Appeals %e!ision affir&in' the %is&issal of the Court of
irst (nstan!e of the !o&plaint for %a&a'es file% b) petitioners a'ainst the
respon%ents *uanito Rosario an% Cresen!ia Rosario.
+n ,a) -, 1965, petitioner Bernabe Castillo .in his o#n behalf, an% in behalf of Serapion
Castillo #ho has sin!e then be!o&e %e!ease%, an% /ulo'io Castillo, his &inor
!hil%0 an% 1enerosa 1alan' Castillo fi'ure% in a vehi!ular a!!i%ent #ith private
respon%ents *uanito Rosario an% Cresen!ia Rosario at Ba'a!, 2illasis, 3an'asinan
!ausin' in4uries to their persons an% %a&a'es to their respe!tive vehi!les.
The parties have their o#n version of #hat a!tuall) happene% on that fateful %a). /a!h
part) is pointin' to the ne'li'en!e b) the other as the pro5i&ate !ause of the
a!!i%ent.
6hile the !ase #as pen%in' in the Court of irst (nstan!e of ,anila, the
3rovin!ial is!al of 3an'asinan file an infor&ation %ate% Septe&ber -9. 1965
a'ainst *uanito Rosario for %ouble ph)si!al in4uries, %ouble less serious ph)si!al
in4uries, an% %a&a'e to propert) thru re!$less i&pru%en!e in the Court of irst
(nstan!e of 7r%aneta. Rosario #as prose!ute% an% !onvi!te% in the !ri&inal !ase.
Castillo then appeale% to the Court of Appeals #hi!h ren%ere% a %e!ision
a!8uittin' hi& fro& the !ri&e !har'e% on the 'roun% that his 'uilt has not been
prove% be)on% reasonable %oubt. +n the other han%, the Court of irst (nstan!e of
,anila ren%ere% a %e!ision on the basis of the testi&onies an% evi%en!e sub&itte%
b) the petitioners as #ell as the re!or%s of the !ase, %is&issin' the !o&plain of
the petitioners a'ainst private respon%ents as #ell as the !ounter!lai& of private
respon%ents a'ainst the petitioners. +n *anuar) -9, 1973, petitioners appeale% to
the Court of Appeals #hi!h then affir&e% the %e!ision of the Court of irst
(nstan!e of ,anila as it foun% no ne'li'en!e !o&&itte% b) *uanito Rosario to
#arrant an a#ar% of %a&a'es to the petitioners. Hen!e, the present petition for
revie# on !ertiorari.
(ssue" 6hether or not the 4u%'e&ent of a!8uittal e5tin'uishes !ivil liabilit) base%
on the sa&e in!i%ent.
Rulin'" :es. The Court of Appeals; fin%in's that the !ollision #as not %ue to the
ne'li'en!e of *uanito Rosario but Bernabe Castillo;s o#n a!t of %rivin' #as
a!tuall) the pro5i&ate !ause of the !ollision. 6ith su!h fin%in's an% !itin' the
!ases Corpus vs 3a4e, -< SCRA 1=6-, 1=69, 1=67> araon vs 3riela, -9 SCRA
5<-, 5<3> ?e Soriano vs Alborno@, 9< 3hil. 7<5, 7<77<<> Tan vs Stan%ar% 2a!uu&
+il Co., 91 3hil. 67-, 675, the Court of Appeals e5onerate% Rosario fro& the !ivil
liabilit) on the 'roun% that the alle'e% ne'li'en!e %i% not e5ist.
57. PADUA vs ROBLES
Facts: The citation of the case was a negligent act, homicide through
reckless imprudence fled to driver Romeo Punzalan and defendants -
appellees as subsidiary liable, which give rise to two separate
liabilities, namely (! the civil liability arising from crime or culpa
criminal and ("! the liability arising from civil negligence or so called
culpa a#uiliana$
Issue:%hether or not that negligent act of Punzalan gives rise to the
two separate and independent liabilities$
Held: &t is by now settled beyond all cavil as to dispense with the
citation of 'urisprudence, that a negligent act such as that committed
by Punzalan gives rise to at least two separate and independent kinds
of liabilities, (! the civil liability arising from crime or culpa criminal
and ("! the liability arising from civil negligence or the so-called culpa
a#uiliana$ These two concepts of fault are so distinct from each other
that e(oneration from one does not result in e(oneration from the
other$ )d'ectively and substantively, they can be prosecuted separately
and independently of each other, although )rticle "** of the +ivil
+ode precludes recovery of damages twice for the same negligent act
or omission, which means that should there be varying amounts
awarded in two separate cases, the plainti, may recover, in e,ect,
only the bigger amount$ That is to say, if the plainti, has already been
ordered paid an amount in one case and in the other case the amount
ad'udged is bigger, he shall be entitled in the second case only to the
e(cess over the one f(ed in the frst case, but if he has already been
paid a bigger amount in the frst case, he may not recover anymore in
the second case$ Thus, in the case at bar, inasmuch as Punzalan had
already been sentenced to pay the herein petitioners the amounts
above-stated, in the subse#uent criminal case, he could not be
ad'udged to pay a higher amount

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