Carandang v. Santiago

Summary

Carandang sought civil damages from the Valentons after Tomas Valenton Jr. was convicted of frustrated homicide against him. The Manila trial court suspended the civil case pending the criminal appeal. The Supreme Court reversed via certiorari, holding that Article 33 of the Civil Code permits independent civil actions for physical injuries regardless of the specific crime charged. The Court interpreted 'physical injuries' broadly to include any bodily harm, not just the technical crime under the Penal Code, reasoning that it should be understood consistently with the general terms 'defamation' and 'fraud' in the same article. This established the principle that civil damage suits can proceed independently of related criminal cases.