Bernardo Jocson v. Redencion Glorioso

Summary

This Supreme Court case established that the dismissal of a civil action for quasi-delict (culpa aquiliana) does not bar the enforcement of subsidiary civil liability under Article 103 of the Revised Penal Code against an employer whose employee was criminally convicted. The parents of a deceased child successfully enforced subsidiary liability against a jeepney owner after the driver was convicted of homicide through reckless imprudence but proved insolvent. The Court distinguished between two different legal remedies: quasi-delict under the Civil Code and subsidiary liability under the Revised Penal Code, holding these involve different causes of action. The decision reinforced the Martinez v. Barredo doctrine that criminal conviction conclusively binds the subsidiarily liable employer, and emphasized that lower courts cannot review or interfere with higher court decisions on appeal.