- Petitioner
- Benigno C. Asis and Virginia P. Asis
- Respondent
- Asterio Ronquillo
- Citation
- G.R. No. 220385
- Court
- Supreme Court
- Decided
- June 6, 2018
Civil liability for death and multiple injuries caused by vehicular accident, determination of proper damages and compensation
Summary
This case arose from a vehicular accident that killed Dr. Alvin P. Asis and injured others. While respondent Asterio Ronquillo was acquitted in the criminal case for reckless imprudence resulting in homicide, he was found civilly liable for negligence. The Regional Trial Court awarded various damages totaling over P3.5 million. The Court of Appeals modified the award, deleting actual damages and attorney's fees while awarding temperate damages. The Supreme Court partially granted the petition, adding mandatory civil indemnity of P50,000.00 for death under Article 2206 of the Civil Code, which the lower courts failed to award. The decision clarifies that civil indemnity for death is mandatory in quasi-delict cases and that temperate damages are proper when pecuniary loss is established but the exact amount cannot be proven. The case demonstrates the distinction between criminal acquittal and civil liability standards.
Focus of dispute
Civil liability for death and multiple injuries caused by vehicular accident, determination of proper damages and compensation
Legal facts
Vehicular accident caused the death of Dr. Alvin P. Asis and multiple serious and slight physical injuries to others. Consolidated criminal case for reckless imprudence resulting in homicide and multiple physical injuries (Criminal Case No. 6757) and separate civil case for damages and attorney's fees (Civil Case No. 1429) filed by petitioners (parents of deceased) against respondent Asterio Ronquillo before RTC Branch 6, Prosperidad, Agusan del Sur.
Judgement and reasoning
Court of Appeals (CA): Affirmed finding of negligence and award of compensation for loss of earning capacity. Deleted award of actual damages and attorney's fees. Reduced moral damages to P50,000.00 but awarded temperate damages of P50,000.00.
Regional Trial Court (RTC) Branch 6, Prosperidad, Agusan del Sur: Acquitted respondent in criminal case on ground of reasonable doubt. However, found respondent failed to exercise due diligence of a good father of a family in civil case. Held him civilly liable to heirs of Dr. Asis and awarded actual and moral damages of P100,000.00 each, attorney's fees of P100,000.00, and loss of earning capacity of P3,357,975.10.
Supreme Court (SC): Partially granted petition. Found RTC and CA erred in failing to award mandatory civil indemnity for death. Applied Article 2206 of Civil Code requiring civil indemnity for death caused by crime or quasi-delict. Set civil indemnity at P50,000.00. Affirmed CA's award of temperate damages in lieu of actual damages due to insufficient proof. Upheld deletion of attorney's fees for lack of factual and equitable justification.