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Torts and Damages Case Digest: Heirs of Pedro Tayag v. Hon. Fernando S. Alcantara, et al. (1980)

G.R. No. L-50959 July 23, 1980
Lessons Applicable: Elements of quasi-delict (Torts and Damages)

  • September 2, 1974 a.m.: Philippine Rabbit Bus bump Pedro Tayag Sr. was riding on a bicycle along MacArthur Highway at Bo. San Rafael, Tarlac driven by Romeo Villa, as a result of which he sustained injuries which caused his instantaneous death
  • Judge granted the motion, and consequently, suspended the hearing of Civil Case while criminal case is pending judgment
  • RTC: acquitting the Romeo Villa of the crime of homicide on the ground of reasonable doubt
  • subsequently, the civil case was dismissed
ISSUE: W/N the civil case based on quasi-delict should be barred by the acquittal in a criminal case

HELD: NO. order of dismissal should be, as it is hereby set aside
  • Art. 31. When the civil action is based on an obligation not arising from the act or commission complained of as a felony. such civil action may proceed independently of the criminal proceedings and regardless of the result of the latter.
  • All the essential averments for a quasi delictual action are present, namely: (1) an act or omission constituting fault or negligence on the part of private respondent; (2) damage caused by the said act or commission; (3) direct causal relation between the damage and the act or commission; and (4) no pre-existing contractual relation between the parties