In the Philippines, an acquittal in a criminal case does not always mean freedom from civil liability. However, in cases of reckless imprudence, the Supreme Court clarified that when an acquittal is based on a finding that the act or omission did not exist, or the accused did not commit the imputed act, the associated civil liability is extinguished. This means that if a court determines that the accused was not negligent, they cannot be held civilly liable for damages arising from the incident.

Traffic Accident or Tainted Acquittal? When Recklessness Claims Hit a Dead End

This case revolves around a traffic incident in Sibulan, Negros Oriental, where Jeffrey Reso Dayap was charged with reckless imprudence resulting in homicide, less serious physical injuries, and damage to property. The Municipal Trial Court (MTC) acquitted Dayap, finding that the prosecution failed to prove his guilt beyond reasonable doubt. Dissatisfied, the respondents, Pretzy-Lou Sendiong, Genesa Sendiong, Elvie Sy, and Dexie Duran, sought to challenge the MTC’s decision, leading to a legal battle that ultimately reached the Supreme Court. At the heart of the dispute was whether the MTC had jurisdiction over the case, and whether the acquittal of Dayap should also extinguish his civil liability.

The Court of Appeals reversed the MTC’s decision, ruling that the Regional Trial Court (RTC) had jurisdiction, as the damages claimed exceeded the MTC’s jurisdictional limit. The appellate court also believed that the MTC should have considered the aggravating circumstance of abandonment. However, the Supreme Court disagreed, holding that the MTC correctly took cognizance of the case based on the original information. The Supreme Court emphasized the importance of determining jurisdiction based on the law in force at the time the action was instituted, citing Republic Act (R.A.) No. 7691, which expands the jurisdiction of first-level courts.

Section 32(2) of Batas Pambansa Bilang 129 had already been amended by R.A. No. 7691… [stating] “that in offenses involving damage to property through criminal negligence, they shall have exclusive original jurisdiction thereof.”

The Supreme Court highlighted that the offense charged was reckless imprudence resulting in homicide, less serious physical injuries, and damage to property, which falls under the jurisdiction of the MTC. The Court found that since the MTC had acquitted Dayap due to insufficiency of evidence, the crucial question became whether that acquittal also extinguished any potential civil liability.

The Supreme Court referenced the rule that an acquittal does not automatically preclude a judgment against the accused on the civil aspect, unless there is a finding that the act or omission from which the civil liability may arise did not exist, or the accused did not commit the imputed acts. Building on this principle, the Supreme Court scrutinized the MTC’s decision, noting its conclusion that no evidence linked Dayap to the crime and that the prosecution failed to establish his responsibility. This directly addressed the existence of the act or omission giving rise to civil liability.

Based on the MTC’s findings, the Supreme Court determined that the acquittal was based on the fact that Dayap was not proven to have committed the act of reckless imprudence. In other words, the court determined the basis for civil liability did not exist. The Supreme Court made a point to explicitly confirm Dayap’s civil liability was extinguished by his acquittal.

A scrutiny of the MTC’s decision supports the conclusion that the acquittal was based on the findings that the act or omission from which the civil liability may arise did not exist and that petitioner did not commit the acts or omission imputed to him; hence, petitioner’s civil liability has been extinguished by his acquittal.

FAQs

What was the key issue in this case?	The main issue was whether the acquittal of Jeffrey Reso Dayap in the criminal case for reckless imprudence also extinguished his civil liability, and whether the MTC had jurisdiction over the case.
What is reckless imprudence under Philippine law?	Reckless imprudence involves committing an act or omission without malice, but with a lack of foresight, skill, prudence, or diligence, causing damage or injury to another. Article 365 of the Revised Penal Code penalizes such acts.
When does an acquittal extinguish civil liability?	An acquittal extinguishes civil liability when the court finds that the act or omission from which the civil liability may arise did not exist, or the accused did not commit the imputed acts or omission.
What is a demurrer to evidence?	A demurrer to evidence is a motion filed by the defendant after the prosecution rests its case, arguing that the evidence presented is insufficient to warrant a conviction.
What is the effect of granting a demurrer to evidence?	If a court grants a demurrer to evidence and acquits the accused, that decision generally cannot be appealed because that would be to put the accused in double jeopardy.
What was the Court of Appeals’ ruling in this case?	The Court of Appeals ruled that the RTC had jurisdiction and remanded the case for proper disposition, finding that the criminal case involved a higher civil liability amount and an aggravating circumstance of abandonment.
How did the Supreme Court rule on the jurisdiction issue?	The Supreme Court ruled that the MTC had the correct jurisdiction over the case because RA 7691 gave the MTC exclusive original jurisdiction over offenses of that type.
Did the Supreme Court find the accused civilly liable?	No, the Supreme Court held that the accused’s civil liability was extinguished. Since the MTC ruling for the accused to be acquitted was based on the court finding that the accused did not commit the act in the first place, the ruling served to clear all liability (both criminal and civil).

The Supreme Court’s decision in this case clarifies the relationship between criminal and civil liability in reckless imprudence cases. The ruling underscores that a court’s finding that an act or omission never occurred will free a defendant of all civil and criminal charges. The case reaffirms the importance of jurisdictional rules and offers a framework for civil responsibility.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Jeffrey Reso Dayap v. Pretzy-Lou Sendiong, G.R. No. 177960, January 29, 2009