The Supreme Court held that an acquittal in a criminal case does not automatically absolve the accused from civil liability. Even if a person is acquitted due to reasonable doubt, they can still be held civilly liable if their negligence is established by a preponderance of evidence. This means that victims of negligence can seek compensation for damages even if the negligent party is not convicted of a crime.

From Criminal Acquittal to Civil Accountability: Unpacking the Aftermath of a Deadly Collision

The case arose from a tragic head-on collision between a JC Liner bus driven by Sonny Romero and an Apego Taxi driven by Jimmy Padua. The accident resulted in multiple deaths and serious injuries, leading to criminal charges against Romero for reckless imprudence resulting in multiple homicide and serious physical injuries. Despite being acquitted in the criminal case due to the court’s inability to ascertain his recklessness beyond a reasonable doubt, the Municipal Trial Court (MTC) found Romero civilly liable to the victims’ heirs. This ruling was subsequently affirmed by the Regional Trial Court (RTC) and the Court of Appeals (CA), leading Romero to appeal to the Supreme Court, arguing that his acquittal should absolve him of any liability.

The Supreme Court, in its resolution, firmly disagreed with Romero’s position, citing the fundamental principle that every person criminally liable is also civilly liable, provided the felonious act or omission results in damage or injury to another. However, it also emphasized that the reverse isn’t always true, as highlighted in Section 2, Rule 111 and Section 2, Rule 120 of the Rules of Court:

Sec. 2. When separate civil action is suspended.–xxx

The extinction of the penal action does not carry with it extinction of the civil action. However, the civil action based on delict shall be deemed extinguished if there is a finding in a final judgment in the criminal action that the act or omission from which the civil liability may arise did not exist. (emphasis supplied)

Sec. 2. Contents of the judgment.–xxx

In case the judgment is of acquittal, it shall state whether the evidence of the prosecution absolutely failed to prove the guilt of the accused or merely failed to prove his guilt beyond reasonable doubt. In either case, the judgment shall determine if the act or omission from which the civil liability might arise did not exist. (emphasis supplied)

Building on this principle, the Court clarified that an acquittal only extinguishes civil liability when the court explicitly declares that the fact from which civil liability might arise did not exist. The Court also emphasized a critical distinction: an acquittal based on reasonable doubt does not preclude a finding of civil liability, which requires only a preponderance of evidence. This means the evidence may not prove criminal negligence beyond a reasonable doubt but can still sufficiently demonstrate negligence for civil liability purposes.

The Court highlighted that the MTC’s decision explicitly stated that while Romero’s guilt wasn’t established beyond a reasonable doubt, he could still be held civilly liable. Further, the RTC pointed out the absence of any finding that the act giving rise to Romero’s civil liability didn’t exist. The CA also echoed this sentiment, emphasizing that Romero’s acquittal stemmed from the prosecution’s failure to prove his guilt beyond a reasonable doubt, not from the absence of the act itself. Thus, his civil liability for the consequences of the collision remained a separate issue.

The Supreme Court underscored that even if criminal negligence is not proven, civil liability can still arise if negligence is established by a preponderance of evidence. Preponderance of evidence simply means that it is more likely than not that the defendant was negligent. While absolute certainty is not required, the evidence must suggest that the defendant’s actions more probably caused the damage.

Regarding the second issue raised by Romero, the Court reiterated that it is not a trier of facts and generally does not re-evaluate evidence already presented during trial. Since the MTC, RTC, and CA uniformly found that Jimmy Padua, not Gerardo Breis, Sr., was driving the taxi at the time of the accident, the Court upheld this factual finding.

FAQs

What was the key issue in this case?	The key issue was whether an acquittal in a criminal case for reckless imprudence automatically absolves the accused of civil liability arising from the same act.
What is the difference between proof beyond reasonable doubt and preponderance of evidence?	Proof beyond reasonable doubt is the standard required for criminal convictions, demanding near certainty of guilt. Preponderance of evidence, used in civil cases, requires only that it is more likely than not that the defendant is liable.
Does an acquittal in a criminal case always mean no civil liability?	No, an acquittal only extinguishes civil liability if the court explicitly states that the act or omission giving rise to civil liability did not exist.
What does ‘civil liability ex delicto‘ mean?	Civil liability ex delicto arises from the commission of a crime or delict, where the offender must compensate the victim for damages caused by the criminal act.
What was the basis for the lower courts finding Sonny Romero civilly liable?	The lower courts found Sonny Romero civilly liable because, while his criminal recklessness wasn’t proven beyond a reasonable doubt, negligence was established by a preponderance of evidence.
Can the Supreme Court review factual findings of lower courts?	Generally, the Supreme Court does not review factual findings of lower courts, especially if the findings are consistent across multiple courts. Exceptions exist, but were not applicable in this case.
What is the significance of Section 2, Rule 111 and Section 2, Rule 120 of the Rules of Court in this case?	These sections clarify that the extinction of a penal action does not automatically extinguish the civil action, unless there’s a finding that the act or omission from which the civil liability arises did not exist.
Who was driving the taxi at the time of the accident?	The MTC, RTC, and CA all uniformly found that Jimmy Padua was driving the taxi at the time of the accident, a finding the Supreme Court did not disturb.

In conclusion, this case clarifies the distinction between criminal and civil liability, emphasizing that an acquittal in a criminal case does not automatically absolve the accused of civil responsibility. Establishing negligence by a preponderance of evidence remains sufficient grounds for imposing civil liability, even in the absence of criminal conviction, offering recourse to victims seeking compensation for damages.

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: Sonny Romero v. People, G.R. No. 167546, July 17, 2009