Rolito Calang v. People

Summary

This case involves a vehicular accident resulting in multiple deaths and injuries, where bus driver Rolito Calang was convicted of reckless imprudence. The key legal issue was the proper determination of employer Philtranco's civil liability. The Supreme Court corrected a fundamental error made by lower courts, distinguishing between delict (criminal liability) and quasi-delict (pure civil liability). Since Calang's liability arose from a criminal conviction, the Court ruled that Philtranco's liability should be subsidiary under Articles 102-103 of the Revised Penal Code, not joint and several under Civil Code provisions on quasi-delict. This establishes important jurisprudence on employer liability in criminal cases, clarifying that quasi-delict provisions apply only to purely civil actions, while criminal convictions trigger subsidiary liability rules under the Revised Penal Code.