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PEOPLE V. MANIAGO

FACTS

Petitioner Ruben Maniago was the owner ofshuttle buses which were used in transportingemployees of the Texas Instruments, Inc. fromBaguio City proper to its plant site at Loakan,Baguio City. One of his buses figured in avehicular accident with a passenger jeepney

owned by private respondent Alfredo Boadoalong Loakan Road, Baguio City. As a result ofthe accident, a criminal case for recklessimprudence resulting in damage to propertyand multiple physical injuries was filed againstpetitioners driver, Herminio Andaya, with theRTC of Baguio City. A month later, a civil casefor damages was filed by private respondentBoado against petitioner himself. Petitionermoved for the suspension of the proceedings inthe civil case against him, citing the pendencyof the criminal case against his driver. Hefurther allege that the civil action against him

was impliedly instituted in the criminal actionpreviously filed against his employee becauseprivate respondent did not reserve his right tobring this action separately.

ISSUE BEFORE THE RTC

Whether or not petitioners motion for thesuspension of the proceedings in the civil caseagainst him during the pendency of the criminalcase against his driver.

RULING OF THE RTC

The trial court denied petitioners motion on theground that pursuant to the Civil Code, theaction could proceed independently of thecriminal action, in addition to the fact that thepetitioner was not the accused in the criminalcase.

MODE OF APPEAL BEFORE THE CA

Petition for prohibition and certiorari

ISSUE BEFORE THE CA

Whether or not the civil action could proceedindependently of the criminal case taking into

account that no reservation of the right to bringit separately had been made in the criminalcase

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 proceedindependently of the criminal case taking into

account that no reservation of the right to bringit separately had been made in the criminalcase

RULING OF THE SC

The decision appealed from is reserved and thecomplaint against petitioner is dismissed. Rule111 Section 1 clearly requires that a reservationmust be made to institute separately all civilactions for the recovery of civil liability,otherwise they will be deemed to have beeninstituted with the criminal case. Such civilactions are not limited to those which arisefrom the offense charged, but it also includes

recovery of indemnity under the Revised PenalCode, and damages under Articles 32, 33, 34and 2176 of the Civil Code of the Philippinesarising from the same act or omission of theaccused. In other words, the right of the injuredparty to sue separately for the recovery of thecivil liability whether arising from crimes (exdelicto) or from quasi-delict under Article 2176of the Civil Code must be reserved otherwisethey will be deemed instituted with the criminalaction.

SAN ILDEFONSO LINES V. CA

FACTS

A passenger bus of herein petitioner SanIldefonso Lines, Inc. (hereafter, SILI) figured in avehicular mishap with a Toyota Lite Ace Vanbeing driven by its owner Annie U. Jao at theintersection of Julia Vargas Avenue andRodriguez Lanuza Avenue in Pasig, MetroManila, totally wrecking the Toyota van andinjuring Ms. Jao and her two (2) passengers inthe process.

A criminal case was thereafter filed with theRTC of Pasig charging the driver of the bus,herein petitioner Eduardo Javier, with recklessimprudence resulting in damage to propertywith multiple physical injuries. About fourmonths later, private respondent PioneerInsurance and Surety Corporation (PISC), asinsurer of the van and subrogee, filed a case fordamages against petitioner SILI with the RTC ofManila, seeking to recover the sums it paid theassured under a motor vehicle insurance policyas well as other damages.

Petitioners filed a Manifestation and Motion toSuspend Civil Proceedings grounded on thependency of the criminal case against petitionerJavier in the Pasig RTC and the failure ofrespondent PISC to make a reservation to file aseparate damage suit in said criminal action.

ISSUE BEFORE THE RTC

Whether or not the civil proceedings besuspended on the ground of the pendency ofthe criminal case against petitioner Javier in thePasig RTC and the failure of respondent PISC to

make a reservation to file a separate damagesuit in said criminal action.

RULING OF THE RTC

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The RTC denied the Motion. It holds thatplaintiff may legally institute the present civilaction even in the absence of a reservation inthe criminal action. This is so because it fallsamong the very exceptions to the rule cited bythe movant.

MODE OF APPEAL BEFORE THE CA

Petition for certiorari

RULING OF THE CA

The CA upholds the ruling of the RTC. Even ifthere was no reservation in the criminal caseand that the civil action was not filed before thefiling of the criminal action but before theprosecution presented evidence in the criminalaction, and the judge handling the criminal casewas informed thereof, then the actual filing ofthe civil action is even far better than acompliance with the requirement of an expressreservation that should be made by theoffended 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 anindependent civil action based on quasi-delictunder Article 2176 of the Civil Code be filed ifno reservation was made in the said criminalcase?

2) Can a subrogee of an offended partymaintain an independent civil action during thependency of a criminal action when noreservation of the right to file an independentcivil action was made in the criminal action anddespite the fact that the private complainant isactively participating through a privateprosecutor in the aforementioned criminalcase?

RULING: WHEREFORE, premises considered, theassailed decision of the Court of Appeals dated

February 24, 1995 and the Resolution datedApril 3, 1995 denying the motion forreconsideration thereof are hereby REVERSEDand SET ASIDE. The "MANIFESTATION ANDMOTION TO SUSPEND CIVIL PROCEEDINGS" filedby petitioners is GRANTED.

RATIO: Now that the necessity of a priorreservation is the standing rule that shallgovern the institution of the independent civilactions referred to in Rule 111 of the Rules ofCourt, past pronouncements that view thereservation requirement as an "unauthorized

amendment" to substantive law - i.e., the CivilCode, should no longer be controlling. Theremust be a renewed adherence to the time-honored dictum that procedural rules aredesigned, not to defeat, but to safeguard theends of substantial justice. And for this noble

reason, no less than the Constitution itself hasmandated this Court to promulgate rulesconcerning the enforcement of rights with theend in view of providing a simplified andinexpensive procedure for the speedydisposition of cases which should not diminish,increase or modify substantive rights. Far fromaltering substantive rights, the primary purposeof the reservation is, to borrow the words of the

Court in "Caos v. Peralta"Clearly then, private respondent PISC, assubrogee under Article 2207 of the Civil Code, isnot exempt from the reservation requirementwith respect to its damages suit based on quasi-delict arising from the same act or omission ofpetitioner Javier complained of in the criminalcase. As private respondent PISC merelystepped into the shoes of Ms. Jao (as owner ofthe insured Toyota van), then it is bound toobserve the procedural requirements which Ms.Jao ought to follow had she herself institutedthe civil case.