- Petitioner
- Mendoza
- Respondent
- Arrieta
- Citation
- G.R. No. L-32599
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Melencio-Herrera, J.
- Decided
- June 29, 1979
Summary
This case establishes important distinction between civil liability arising from crime (culpa criminal) under Revised Penal Code and quasi-delict (culpa aquiliana) under Civil Code Articles 2176-2177. Supreme Court ruled that separate civil action for quasi-delict may proceed independently of criminal proceedings without need for reservation, as these constitute different causes of action with distinct legal foundations. However, where accused is acquitted on ground that facts giving rise to civil liability did not exist, civil action is extinguished. Case demonstrates that same negligent act may produce either criminal civil liability or independent quasi-delict action, each with separate procedural requirements and substantive legal basis.