MENDOZA v ARRIETA

Facts : A three-way vehicular accident occurred involving a Mercedes Benz driven by Petitioner
Mendoza, a private jeep driven by Respondent Salazar, and a gravel/sand truck owned by
Respondent Timbol and driven by Montoya.
Two separate Informations for Reckless Imprudence Causing Damage to Property were
filed against Salazar and Montoya (both criminal cases):
1. Case against Montoya for causing damage to the jeep owned by Salazar (by hitting it at
the rear, causing it to hit Mendozas Benz)
2. Case against Salazar for causing damage to his Benz
TC found Montoya guilty of damage to property through reckless imprudence, and absolved
Salazar of civil and criminal liability, finding that collision between Salazars jeep and Benz
was the result of having been bumped by the truck driven by Montoya. Mendoza was not
awarded damages since his complaint was against Montoya and not Salazar.
Mendoza filed civil cases against Salazar and Timbol (owner of truck driven by Montoya) for
damages sustained by his car as a result of the collision.
Respondent Judge dismissed complaint against Timbal on the grounds that it was barred
by a prior judgement in the criminal cases, wherein no reservation to file a separate civil
case was made and that it failed to state a cause of action. He also dismissed complaint
against Salazar because of non-compliance with the Rules of Court with regard to
reservation in filing a separate civil action.
Issue/s : 1. WON Petitioner is entitled to damages from Timbol
2. WON Petitioner is entitled to damages from Salazar
Held : 1. YES. In so far as Timbol is concerned, the civil case is not barred by the fact that petitioner failed
to reserve, in the criminal action, his right to file an independent civil action based on quasidelict. Respondent judge committed an error when he dismissed the civil suit against Timbol as the
said case may proceed independently of the criminal proceedings regardless of the result of the latter.
The same negligent act causing damages may produce a civil liability arising from crime or create
an action for quasi-delict or culpa extra-contractual. The former is a violation of the criminal law,
while the latter is a distinct and independent negligence having its own foundation and
individuality.

2. NO. In as much as civil liability co-exists with criminal responsibility in cases involving
negligence, the offended party has the option between an action for enforcement of civil
liability based on culpa criminal or an action for recovery of damages based on culpa
aquiliana. In the case of the former, the action for enforcement of civil liability is deemed
simultaneously instituted with the criminal action unless expressly reserved for separate
application by the offended party. Petitioner had opted to base his cause of action against
Salazar on culpa criminal as evidenced by his active participation and intervention in the
prosecution of the criminal suit against Salazar. The latters civil liability was involved in
the criminal action until its termination.
An independent civil action would also not lie due to the trial courts pronouncement that
according to the facts of the case, Salazar cannot be held liable for the damages sustained by
Mendoza. (Rule 111 ROC. Extinction of penal action does not carry with it extinction of the
civil unless the extinction proceeds from a declaration in final judgement that the fact from
which the civil might arise did not exist)