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Torts and Damages Case Digest: Bernabe Castillo et al v. Hon. Court of Appeals, et al (1989)

G.R. No. 48541 August 21, 1989
Lessons Applicable: Quasi-delict (Torts and Damages)

  • Barnabe Castillo's Version (May 2, 1965, 2:00 p.m.)
    • Bernabe Castillo was driving his jeep on the right lane of the McArthur Highway with Generosa Castillo, his wife, father Serapion Castillo, seated in front and Eulogio Castillo, then a minor child at the rate of 25 kms/hr
    • Juanito Rosario, with his wife, Cresencia Rosario drove his car speeding and oncoming the same lane for the purpose of overtaking a cargo truck
    • To evade collission, Bernabe swerved his jeep hard right and the car rested on the shoulder of the right lane as the jeep's rear left wheel was on the road, leaving short tiremarks behind it while the rear left long tire-marks
      • The jeep suffered a shattered windshield, pushed-in radiator. The left mid-portion of its bumper badly dented. The car had a flat tire on its right front wheel; its right fender badly dented as the headlamp on top of it. The bumber stooped downward.
      • Bernabe's patella on his right knee was fractured and he suffered serious physical injuries, in other parts of his body. Serapion Castillo whose head crushed through the windshield and was nearly beheaded, while the other two passengers suffered multiple slight and less serious injuries.
  • Juanito Rosario's Version  (May 2, 1965, 2:30 p.m.)
    • He was about to overtake a slow cargo truck but due to a flat tire, he parked his car on the left shoulder of the road
    • as he was about to get off to fix the flat tire, the car was suddenly bumped by the jeep driven by Bernabe from the opposite direction
  • In the criminal case, Juanito was acquited from the crime for reckless imprudence on the ground that his guilt has not been proved beyond reasonable doubt
    • Court held that the collision was not due to the negligence of Juanito Rosario but it was Castillo's own act of driving the jeep to the shoulder of the road where the car was is the proximate cause of the collision
  • CA affirmed CFI: Dismissed the case against Juanito as well as the counterclaim against Bernabe 
ISSUE: W/N the negligence of Juanito can make him civilly liable despite being acquitted from his criminal charges 

  • Since the civil action is predicated upon Juanito Rosario's alleged negligence which does not exist, it follows that his acquittal in the criminal action, which is already final, carried with it the extinction of civil responsibility arising therefrom
  • findings of facts by the Court of Appeals are conclusive and not reviewable by the Supreme Court