Safeguard Security Agency v. Lauro Tangco

Summary

This landmark case clarifies the distinction between civil liability arising from crime versus quasi-delict, and establishes that victims may choose to pursue quasi-delict actions even when criminal cases exist. Security guard Pajarillo negligently shot and killed Evangeline Tangco when she attempted to deposit her licensed firearm at a bank. The Supreme Court affirmed that respondents' separate civil action was properly based on quasi-delict under Article 2176 of the Civil Code, making employer Safeguard Security Agency directly and solidarily liable under Article 2180. The Court rejected the Court of Appeals' finding that liability should be subsidiary under the Revised Penal Code, emphasizing that the choice of cause of action determines the applicable legal framework. The case reinforces employers' duty to exercise diligence not only in employee selection but also in continuous supervision and training, particularly for security personnel handling sensitive duties.