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PEOPLE V.

MANIAGO FACTS Petitioner Ruben Maniago was the owner of shuttle buses which were used in transporting employees of the Texas Instruments, Inc. from Baguio City proper to its plant site at Loakan, Baguio City. One of his buses figured in a vehicular accident with a passenger jeepney owned by private respondent Alfredo Boado along Loakan Road, Baguio City. As a result of the accident, a criminal case for reckless imprudence resulting in damage to property and multiple physical injuries was filed against petitioners driver, Herminio Andaya, with the RTC of Baguio City. A month later, a civil case for damages was filed by private respondent Boado against petitioner himself. Petitioner moved for the suspension of the proceedings in the civil case against him, citing the pendency of the criminal case against his driver. He further allege that the civil action against him was impliedly instituted in the criminal action previously filed against his employee because private respondent did not reserve his right to bring this action separately. ISSUE BEFORE THE RTC Whether or not petitioners motion for the suspension of the proceedings in the civil case against him during the pendency of the criminal case against his driver. RULING OF THE RTC The trial court denied petitioners motion on the ground that pursuant to the Civil Code, the action could proceed independently of the criminal action, in addition to the fact that the petitioner was not the accused in the criminal case. MODE OF APPEAL BEFORE THE CA Petition for prohibition and certiorari ISSUE BEFORE THE CA Whether or not the civil action could proceed independently of the criminal case taking into account that no reservation of the right to bring it separately had been made in the criminal case RULING OF THE CA CA dismissed the petition MODE OF APPEAL BEFORE THE SC Petition for review on certiorari under Rule 65 ISSUE BEFORE THE SC Whether or not the civil action could proceed independently of the criminal case taking into account that no reservation of the right to bring it separately had been made in the criminal case RULING OF THE SC

The decision appealed from is reserved and the complaint against petitioner is dismissed. Rule 111 Section 1 clearly requires that a reservation must be made to institute separately all civil actions for the recovery of civil liability, otherwise they will be deemed to have been instituted with the criminal case. Such civil actions are not limited to those which arise from the offense charged, but it also includes recovery of indemnity under the Revised Penal Code, and damages under Articles 32, 33, 34 and 2176 of the Civil Code of the Philippines arising from the same act or omission of the accused. In other words, the right of the injured party to sue separately for the recovery of the civil liability whether arising from crimes (ex delicto) or from quasi-delict under Article 2176 of the Civil Code must be reserved otherwise they will be deemed instituted with the criminal action. SAN ILDEFONSO LINES V. CA FACTS A passenger bus of herein petitioner San Ildefonso Lines, Inc. (hereafter, SILI) figured in a vehicular mishap with a Toyota Lite Ace Van being driven by its owner Annie U. Jao at the intersection of Julia Vargas Avenue and Rodriguez Lanuza Avenue in Pasig, Metro Manila, totally wrecking the Toyota van and injuring Ms. Jao and her two (2) passengers in the process. A criminal case was thereafter filed with the RTC of Pasig charging the driver of the bus, herein petitioner Eduardo Javier, with reckless imprudence resulting in damage to property with multiple physical injuries. About four months later, private respondent Pioneer Insurance and Surety Corporation (PISC), as insurer of the van and subrogee, filed a case for damages against petitioner SILI with the RTC of Manila, seeking to recover the sums it paid the assured under a motor vehicle insurance policy as well as other damages. Petitioners filed a Manifestation and Motion to Suspend Civil Proceedings grounded on the pendency of the criminal case against petitioner Javier in the Pasig RTC and the failure of respondent PISC to make a reservation to file a separate damage suit in said criminal action. ISSUE BEFORE THE RTC Whether or not the civil proceedings be suspended on the ground of the pendency of the criminal case against petitioner Javier in the Pasig RTC and the failure of respondent PISC to make a reservation to file a separate damage suit in said criminal action. RULING OF THE RTC

The RTC denied the Motion. It holds that plaintiff may legally institute the present civil action even in the absence of a reservation in the criminal action. This is so because it falls among the very exceptions to the rule cited by the movant. MODE OF APPEAL BEFORE THE CA Petition for certiorari RULING OF THE CA The CA upholds the ruling of the RTC. Even if there was no reservation in the criminal case and that the civil action was not filed before the filing of the criminal action but before the prosecution presented evidence in the criminal action, and the judge handling the criminal case was informed thereof, then the actual filing of the civil action is even far better than a compliance with the requirement of an express reservation that should be made by the offended party before the prosecution presented its evidence. MODE OF APPEAL BEFORE THE SC Petition for review on certiorari ISSUE BEFORE THE SC ISSUEs: 1) If a criminal case was filed, can an independent civil action based on quasi-delict under Article 2176 of the Civil Code be filed if no reservation was made in the said criminal case? 2) Can a subrogee of an offended party maintain an independent civil action during the pendency of a criminal action when no reservation of the right to file an independent civil action was made in the criminal action and despite the fact that the private complainant is actively participating through a private prosecutor in the aforementioned criminal case? RULING: WHEREFORE, premises considered, the assailed decision of the Court of Appeals dated February 24, 1995 and the Resolution dated April 3, 1995 denying the motion for reconsideration thereof are hereby REVERSED and SET ASIDE. The "MANIFESTATION AND MOTION TO SUSPEND CIVIL PROCEEDINGS" filed by petitioners is GRANTED. RATIO: Now that the necessity of a prior reservation is the standing rule that shall govern the institution of the independent civil actions referred to in Rule 111 of the Rules of Court, past pronouncements that view the reservation requirement as an "unauthorized amendment" to substantive law - i.e., the Civil Code, should no longer be controlling. There must be a renewed adherence to the timehonored dictum that procedural rules are designed, not to defeat, but to safeguard the ends of substantial justice. And for this noble

reason, no less than the Constitution itself has mandated this Court to promulgate rules concerning the enforcement of rights with the end in view of providing a simplified and inexpensive procedure for the speedy disposition of cases which should not diminish, increase or modify substantive rights. Far from altering substantive rights, the primary purpose of the reservation is, to borrow the words of the Court in "Caos v. Peralta" Clearly then, private respondent PISC, as subrogee under Article 2207 of the Civil Code, is not exempt from the reservation requirement with respect to its damages suit based on quasidelict arising from the same act or omission of petitioner Javier complained of in the criminal case. As private respondent PISC merely stepped into the shoes of Ms. Jao (as owner of the insured Toyota van), then it is bound to observe the procedural requirements which Ms. Jao ought to follow had she herself instituted the civil case.

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