- Petitioner
- Asis
- Respondent
- Ronquillo
- Citation
- G.R. No. 220385
- Court
- Supreme Court
- Division
- First Division
- 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.
Intellegal Wiki · Key Holding
Civil indemnity for a death caused by a crime or quasi-delict is mandatory (Article 2206), even where actual damages are unproven (in which case temperate damages apply).
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.