- Petitioner
- George (Culhi) Hambon
- Respondent
- Court of Appeals
- Citation
- G.R. No. 122150
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Austria-Martinez, J.
- Decided
- March 17, 2003
Summary
George Hambon sued Valentino Carantes for damages arising from a vehicular accident where Carantes' truck injured Hambon. A related criminal case for reckless imprudence was dismissed due to Hambon's failure to appear. The trial court awarded damages, but the Court of Appeals reversed, finding that Hambon failed to reserve his right to file a separate civil action as required by Rule 111. The Supreme Court affirmed, ruling that civil actions for quasi-delict under Article 2176 are impliedly instituted with criminal actions unless properly reserved. The reservation requirement is procedural, not substantive, and serves to avoid multiplicity of suits and promote orderly procedure. Without reservation, the civil action was deemed dismissed with the criminal case.