Irineo Yumul v. Antonio Juliano · G.R. 47690

Petitioner: Irineo Yumul
Respondent: Antonio Juliano
Citation: G.R. No. 47690
Court: Supreme Court
Division: Second Division
Ponente: Laurel, J.
Decided: April 28, 1941

Summary

Father sought civil damages for daughter's death in vehicular accident caused by bus company employee's reckless driving. Trial court awarded damages against driver but absolved employer under Civil Code Article 1903's due diligence defense. Supreme Court reversed, establishing that civil obligations arising from criminal acts must be governed by Penal Code provisions, not Civil Code. Court applied subsidiary civil liability under Revised Penal Code Articles 102-103, making employer liable without due diligence defense. This case clarifies the hierarchical relationship between Civil Code and Penal Code provisions regarding employer liability for employee crimes, establishing that criminal law governs civil obligations arising from criminal acts.

Statutes applied

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By Intellegal Editorial Board · April 28, 1941

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