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Bacolod-Consti Case

The document discusses the doctrine of state immunity and whether respondents are civilly liable for damages in a case where they were acquitted of criminal charges. It analyzes the relationship between criminal and civil liability, the requirements for establishing proximate cause, and finds that the prosecution failed to prove preponderance of evidence to hold respondents civilly liable for damages.

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Joy Paras
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48 views3 pages

Bacolod-Consti Case

The document discusses the doctrine of state immunity and whether respondents are civilly liable for damages in a case where they were acquitted of criminal charges. It analyzes the relationship between criminal and civil liability, the requirements for establishing proximate cause, and finds that the prosecution failed to prove preponderance of evidence to hold respondents civilly liable for damages.

Uploaded by

Joy Paras
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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DOCTRINE OF STATE IMMUNITY

The City of Bacolod v. Phuture Vision Co., Inc., G.R. No. 190289, January 17, 2018

Title of the Case THE CITY OF BACOLOD, HON. MAYOR EVELIO R. LEONARDIA, ATTY.
ALLAN L. ZAMORA and ARCH. LEMUEL D. REYNALDO, in their personal
capacities and in their capacities as Officials of the City of Bacolod,
Petitioners vs. PHUTURE VISIONS CO., INC., Respondent
Brief Background / story

Claims of People / Respondents are liable for criminal and civil damages for Quinto’s death
complainant
Claims of accused No preponderant evidence on record to justify their civil liability
Relevant issue 1.Whether or not the extinction of the respondents’ liability, likewise, carries
with it the extinction of their civil liability
2. Whether or not preponderant evidence exists to hold them civilly liable
for Wilson’s death
Ruling of lower court RTC – Acquitted
CA – Affirmed
Ruling of SC Denied the petition for lack of merit
Reasoning No preponderant evidence exists to hold them liable for damages
Relevant doctrine from the Eclectic or Mixed theory
case Every person criminally liable for a felony is also civilly liable. The civil
liability of such person established in Articles 100, 102 and 103 of the
Revised Penal Code includes restitution, reparation of the damage caused,
and indemnification for consequential damages. When a criminal action is
instituted, the civil action for the recovery of civil liability arising from the
offense charged shall be deemed instituted with it. With the implied
institution of the civil action in the criminal action, the two actions are
merged into one composite proceeding, with the criminal action
predominating the civil.

The prime purpose of the criminal action is to punish the offender in order
to deter him and others from committing the same or similar offense, to
isolate him from society (Classical Theory), and/or to reform and
rehabilitate him (Positivist Theory.)

The sole purpose of the civil action is the indemnification of the private
offended party for the damage or injury he sustained by reason of the
delictual or felonious act of the accused. Extinction of the penal action does
not carry with the extinction of the civil action. However, civil action based
on delict shall be deemed extinguished if there is a finding in the final
judgment in the criminal action that the act or omission does not exist.

A person committing a felony is criminally liable for all the natural and
logical consequences resulting therefrom although the wrongful act done
be different from that which he intended. Proximate cause is that cause
which in natural and continuous sequence, unbroken by an efficient
intervening cause, produces the injury, and without which the result would
not have occurred. There must be a relation of "cause and effect," the
cause being the felonious act of the offender, the effect being the resultant
injuries and/or death of the victim.

HELD: YES. petition is DENIED


 Every person criminally liable for a felony is also civilly liable.
o    The civil liability of such person established in Articles 100, 102 and 103 of the Revised Penal Code includes
restitution, reparation of the damage caused, and indemnification for consequential damages
 GR: When a criminal action is instituted, the civil action for the recovery of civil liability arising from the
offense charged shall be deemed instituted with the criminal action
EX: the offended party waives the civil action, reserves the right to institute it separately or institutes the civil
action prior to the criminal action
 With the implied institution of the civil action in the criminal action, the two actions are merged into one
composite proceeding, with the criminal action predominating the civil.
 The prime purpose of the criminal action is to punish the offender in order to deter him and others from
committing the same or similar offense, to isolate him from society, to reform and rehabilitate him or, in
general, to maintain social order.
 The sole purpose of the civil action is the restitution, reparation or indemnification of the private
offended party for the damage or injury he sustained by reason of the delictual or felonious act of the
accused
o    While the prosecution must prove the guilt of the accused beyond reasonable doubt for the crime charged, it is
required to prove the cause of action of the private complainant against the accused for damages and/or
restitution.
o    Insofar as the civil aspect of the case is concerned, the prosecution or the private complainant is burdened to
adduce preponderance of evidence or superior weight of evidence. – failed
  That the deceased fell or slipped cannot be totally foreclosed because even Garcia testified that the drainage
culvert was dark, and that he himself was so afraid that he refused to join respondents Andres and Pacheco
inside
  failed to adduce proof of any ill-motive on the part of either respondent to kill the deceased before or after the
latter was invited to join them in fishing
 GR: The extinction of the penal action does not carry with it the extinction of the civil action. 
EX: civil action based on delict shall be deemed extinguished if there is a finding in a final judgment in the civil
action that the act or omission from where the civil liability may arise does not exist
 a person committing a felony is criminally liable for all the natural and logical consequences resulting
therefrom although the wrongful act done be different from that which he intended
o    Natural - an occurrence in the ordinary course of human life or events
o    Logical - a rational connection between the act of the accused and the resulting injury or damage
 The felony committed must be the proximate cause of the resulting injury
o    Proximate cause
  cause which in natural and continuous sequence, unbroken by an efficient intervening cause, produces the
injury, and without which the result would not have occurred
  acting first and producing the injury, either immediately, or by setting other events in motion, all constituting a
natural and continuous chain of events, each having a close causal connection with its immediate predecessor
o    There must be a relation of “cause and effect,”
  cause = felonious act of the offender
  effect = resultant injuries and/or death of the victim. 
 The “cause and effect” relationship is not altered or changed because of the
o    pre-existing conditions
  pathological condition of the victim
  predisposition of the offended party
  physical condition of the offended party
o    concomitant or concurrent conditions
  negligence or fault of the doctors
  conditions supervening the felonious act
  tetanus
  pulmonary infection
  gangrene
 not the proximate cause of the resulting injury when:
1.    there is an active force that intervened between the felony committed and the resulting injury, and the active
force is a distinct act or fact absolutely foreign from the felonious act of the accused; or
2.    the resulting injury is due to the intentional act of the victim
 The offender is criminally liable for the death of the victim if his delictual act caused, accelerated or
contributed to the death of the victim.
 the prosecution was burdened to prove the corpus delicti which consists of two things:
1.    first, the criminal act - objective
2.    second, defendant’s agency in the commission of the act - subjective element of crimes
         In homicide (by dolo) and in murder cases, the prosecution is burdened to prove:
1.    the death of the party alleged to be dead
2.    that the death was produced by the criminal act of some other than the deceased and was not the result of
accident, natural cause or suicide
3.    that defendant committed the criminal act or was in some way criminally responsible for the act which
produced the death
Labels: 2005, Case Digest, crim law 1, EX criminally liable civilly liable, G.R. No. 155791, March
16, proximate cause, Quinto v. Andres

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