Scribd
Upload
47 views3 pages

005 DIGESTEDCorpus Vs Paje

1) On December 23, 1956, a bus collision occurred between a Victory Liner bus driven by Felardo Paje and a jeep driven by Clemente Marcia, resulting in Marcia's death and injuries to others. 2) Felardo Paje was criminally charged and convicted but later acquitted on appeal, with the court finding the collision was a pure accident. 3) Clemente Marcia's heirs later filed a separate civil case for damages. The defendants argued this civil case was barred by the criminal acquittal and by the four-year prescriptive period for quasi-delicts under the Civil Code.

Uploaded by

Paul Toguay
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
47 views3 pages

005 DIGESTEDCorpus Vs Paje

1) On December 23, 1956, a bus collision occurred between a Victory Liner bus driven by Felardo Paje and a jeep driven by Clemente Marcia, resulting in Marcia's death and injuries to others. 2) Felardo Paje was criminally charged and convicted but later acquitted on appeal, with the court finding the collision was a pure accident. 3) Clemente Marcia's heirs later filed a separate civil case for damages. The defendants argued this civil case was barred by the criminal acquittal and by the four-year prescriptive period for quasi-delicts under the Civil Code.

Uploaded by

Paul Toguay
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 3

TOGUAY, Paul Jeffrey U.

2019-80129
Block 4

Citation G.R. No. L-24803

Date May 26, 1977

Petitioner LAURA CORPUS, and the minors RICARDO, TERESITA and CORAZON, all surnamed
MARCIA and represented by their mother LAURA CORPUS

Respondent FELARDO PAJE and THE VICTORY LINER TRANSPORTATION CO.

PRINCIPLES/ 1. The four-year prescriptive period began to run from the day the quasi-delict was
DOCTRINES committed, or from December 23, 1956, and the running of the said period was not
interrupted by the institution of the criminal action for reckless imprudence.

FACTS:
On December 23, 1956, a passenger bus of the Victory Liner Transportation Co., Inc., driven by
Felardo Paje, collided within the municipality of Lubao, Pampanga, with a jeep driven by Clemente
Marcia, resulting in the latter's death and in physical injuries to two other persons.

An information for homicide and double serious physical injuries through reckless
imprudence was filed against Felardo Paje in the Court First Instance of Pampanga. The heirs of
Clemente Marcia reserved their right to institute a separate civil action for damages. On November 7,
1960, the accused, Felardo Paje, was found guilty and convicted of the crime charged in the
information.

Said defendant appealed the judgment of conviction to the Court of Appeals.

On November 21, 1961, while defendant's appeal was pending decision in the Court of Appeals,
Clemente Marcia's heirs, namely, his widow, Laura Corpus, and their minor children, instituted in the
Court of First Instance of Rizal a SEPARATE CIVIL ACTION for damages based upon the criminal act
of reckless imprudence against Felardo Paje and the Victory Liner Transportation Co., Inc
On November 9, 1962, the Court of Appeals promulgated its decision in the appeal of Felardo
Paje REVERSING the appealed judgment and acquitting the appellant after finding that the reckless
imprudence CHARGED AGAINST HIM DID NOT EXIST, AND THAT THE COLLISION WAS A
CASE OF PURE ACCIDENT.

On December 29, 1962, the defendants filed in the civil action a motion to dismiss on the
ground that the action was barred by the acquittal by the Court of Appeals of the defendant Felardo
Paje in the criminal action. The motion was denied.

At the pre-trial of the civil case, the defendants asked the court to rule on their special
defense that plaintiffs' cause of action based upon a quasi-delict had prescribed considering that the
complaint was brought four years and eleven months after the collision and that according to Article
1144 of the Civil Code an action based upon a quasi-delict must be instituted within four years. The
lower court, in its order of May 31, 1966, dismissed the complaint on the ground that plaintiffs'
action was based upon a quasi-delict and that it had prescribed.

ISSUE:

1. Whether or not the civil case is barred by the decision of the Court of Appeals as it rendered a
decision that crime was not committed as it was a pure accident.

2. Whether or not the civil complaint of action for damages cannot prosper as it was prescribed.

RULING:

1. YES. The civil case is barred by the decision of the Court of Appeals as it rendered a decision that
crime was not committed as it was a pure accident.

“It is true that one of the plaintiffs in the present case reserved whatever right he may have had
to bring a civil action. This was obviously of no avail, inasmuch as there resulted a judgment for the
defendant, and the plain inference from the foregoing is that a verdict of acquittal must carry with it
exemption from civil responsibility.

In the case at bar, the acquittal of the defendant Felardo Paje by the Court of Appeals in the
criminal action on the ground that the reckless imprudence or criminal negligence charged against
him did not exist and that the collision was a case of pure accident, was a bar to the civil action for
damages for the death of Clemente Marcia, which action was based upon the same criminal negligence
of which the defendant Felardo Paje was acquitted in the criminal action.

2. YES. The civil case is barred due to the prescriptive period of four years for it will begin from the
time the quasi-delict was committed.
“An action upon a quasi-delict must be instituted within four (4) years (Article 1146, Civil Code).”

The four-year prescriptive period began to run from the day the quasi-delict was committed, or from
December 23, 1956, and the running of the said period was not interrupted by the institution of the
criminal action for reckless imprudence.

You might also like

pFad - Phonifier reborn

Pfad - The Proxy pFad of © 2024 Garber Painting. All rights reserved.

Note: This service is not intended for secure transactions such as banking, social media, email, or purchasing. Use at your own risk. We assume no liability whatsoever for broken pages.


Alternative Proxies:

Alternative Proxy

pFad Proxy

pFad v3 Proxy

pFad v4 Proxy