Manantan Vs CA

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MANANTAN vs CA

FACTS:
On the 25th day of September 1982, Fiscal Wilfredo Ambrocio invited Ruben Nicholas to catch
shrimps at his farm and ordered him to borrow the Ford Fiera of Manantan. When Ruben went to
Manantan, the latter wanted to come along. Ambrocio and Ruben Nicolas went to Manantan
Technical School and they drank beer. Thereafter, they went to the farm and consumed one case
of beer. At 12 noon, they went home. After two to three hours, Tabangin, Nicholas and
Manantan went to Ambrocio with a duck and consumed another case of beer. At about 8:30,
Manantan invited them to go bowling and while they were waiting for a vacant alley, they again
drank beer. Thereafter, they went to LBC Night Club and after 1 hour they left to eat arrozcaldo.
As they went home that was the time when they figured into an accident, causing the life of
Nicholas. The petitioner Manantan was charged by the Provincial Fiscal of Isabela with reckless
imprudence resulting to homicide. The provincial fiscal filed this information on June 1, 1983
within the Municipality of Santiago, Isabela. The accused was the driver and person-in-charge of
an automobile with the Plate No. NGA-816. Manantan willfully and recklessly drove the vehicle
in a negligent manner which ended up sideswiping a passenger jeepney. Which caused the
Jeepney to turn turtle twice that ultimately ended with the death of Ruben Nicolas, a passenger of
the jeepney. On a decision dated June 30, 1938 which was later promulgated on August 4, 1988,
the trial court reached a decision in favor of Manantan. With the subsequent turn of events the
private respondent spouses Nicolas filed their notice of appeal on the civil aspect of the trial
courts judgment. The spouses Nicolas prayed that the decision appealed from be modified and
that the appellee be ordered to pay indemnity and damages. The court reached a decision wherein
the Court of Appeals decided in favor of the private respondents. With regards to the civil
liability the court a quo stated that during the time that the accident occurred. Manantan was in a
state of heavily inebriated after consuming at least twelve bottles of beer between 9 a.m. to 11
p.m. The petitioner opted for reconsideration but the appellate court denied it vehemently.
ISSUE: Whether or not the acquittal of the accused also extinguished his civil liability.
RULING:
No, it is quite evident that the law recognizes two different kinds of acquittal, with
entirely different effects regarding the civil liability of the accused. First and foremost, the
grounds pertaining to the acquittal of the accused is not the main reason for the act or omission
complained of as a felony. In this particular instance this relinquish the civil liability for a person
who has been found not to be the perpetrator of any act or omission shall not be and should never
be held liable for such an act or omission. This surmise that there is no delict, civil liability ex
delicto is entirely out of the question and therefore the civil action if there is any. Which will be
instituted should be based on the grounds other the delict that was complained of.
The secondary instance is an acquittal that was based on reasonable doubt regarding the
guilt of the accused has not been duly established. In this case at hand the acquittal was primarily
based on reasonable doubt. It was clearly stated that the accused was recklessly imprudent or
negligent. Which evidently prompted the court to acquit him on the main contention of a
reasonable doubt. Since civil liability is not extinguished in a criminal case if the accused is
acquitted on reasonable doubt. The decision of the Court of Appeals states that the defendant is
civilly liable for negligent and reckless of driving his automobile which was the proximate cause
of the vehicular accident and to indemnify the plaintiff for a sum of money due to the death of
Ruben Nicolas.

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