OBLICON CASE DIGESTS

Virata, et al., vs Ochoa, et al.

G.R. No. L-46179 January 31, 1978

Petitioner: Candida Virata, et al.

Respondents: Victorio Ochoa, et al.
Ponente: J. Fernandez

Facts: On September 24, 1975, Arsenio Virata died after being hit by a passenger jeepney
driven by Maximo Borilla and registered in the name of Victorio Ochoa. The heirs of Virata filed
a case of homicide through reckless imprudence against Borilla in the Court of First Instance
(CFI) of Rizal. Petitioners lawyer made a reservation to file a separate civil action but then later
withdrew it. But pending the criminal case, the petitioners again reserved their right to institute a
separate civil action for damages based on quasi-delict against Borilla and Ochoa, (the driver
and the owner of the jeepney, respectively) in the CFI of Cavite. Private respondents herein filed
a motion to dismiss on the ground that there is a pending criminal action between the same
parties for the same cause. The CFI of Rizal acquitted Borilla on the ground that he caused an
injury by mere accident; and on January 1977, the CFI of Cavite granted the motion to dismiss
the civil action for damages. Hence, this appeal for certiorari.

Issue: Can the petitioners file a separate civil action for damages based on quasi-delict
against Borilla and Ochoa?

Ruling: Yes, It is settled in negligence cases that the aggrieved parties may choose between an
action under the Revised Penal Code or for quasi-delict under Article 2176 of the Civil Code of
the Philippines. What is prohibited by Article 2177 of the same Code is to recover twice for the
same negligent act. Therefore, under the proposed Article 2177, an acquittal from an accusation
of criminal negligence, whether on reasonable doubt or not, shall not be a bar to a subsequent
civil action, not for civil liability arising from criminal negligence, but for damages due to a quasi-
delict or culpa aquiliana. A quasi-delict and an act or omission punishable by law are two
different sources of obligation.

Batchelder vs. Central Bank of the Philippines

G.R. No. L-25071 March 29, 1972

Plaintiff-appellant: George W. Batchelder

Defendant-appellant: Central Bank of the Philippines
Ponente: J. Fernando

Facts: The defendant issued various monetary circulars and resolutions regarding the
exchange rate at which dollars could be re-acquired after being surrendered and sold to it.
Among these is Monetary Board Resolution (MBR) No. 857 which provides that Filipino and
resident American contractors undertaking construction projects in U.S. military bases in the
Philippines shall be authorized to utilize ninety per cent (90%) of the proceeds of their contracts
for the purchase of construction equipment, spare parts, and either supplies, regardless of
commodity classification, to be used in projects inside the U.S. military bases in the Philippines
as well as for the payment of imports of construction equipment, spare parts, and supplies xxx.
To implement the above resolution, defendant issued its Memorandum to Authorized Agent
Banks which provides that: For imports against proceeds of contracts entered into prior to April
25, 1960, the preferred buying rate shall govern, regardless of the present commodity
classifications. It was however modified by MBR No. 695 specifying that the agent bank should,
upon compliance with its terms, credit the contractors account in pesos, the buying rate being
governed by the appropriate rules and regulations. Plaintiff is engaged in the construction
business whose proposal for the construction of the Mindanao Weather Station was accepted
by the U.S. Navy on March 30, 1960. In compliance with the MBRs, plaintiff surrendered to the
defendant, through the latters authorized agents his dollar earnings amounting to U.S. $199,
966. The plaintiff demanded from the defendant that it be allowed to use the balance of the 90%
of his surrendered dollar earnings. However, it was only on 1963, after the plaintiff had filed the
complaint in this case and after full decontrol had been established on 1962, that the defendant
informed the plaintiff that the latter could use at the free market rate the balance of his 90%
surrendered dollar earnings which had not been previously granted by the defendant for his
importations. Hence, this suit to compel the defendant to sell to Batchelder U.S. $170, 210.60 at
the preferred rate of exchange of P2.00 per U.S. $1.00 or to pay him the difference between the
peso cost of such amount at the market rate prevailing on the date of the satisfaction of the
judgment by the lower court in his favor and the peso cost of U.S. $170, 210.60 at said
preferred rate.

Issue: Does the Central Bank of the Philippines issuance of a monetary policy, thereafter
implemented by the appropriate resolutions, regarding the exchange rate at which dollars could
be re-acquired after being surrendered and sold to it create a contractual obligation?

Ruling: No. Considering the fundamental meaning of contracts under (Articles 1305, 1315 and
1319) of the Civil Code, and the nature of the administrative authority of the Monetary Board to
promulgate rules and regulations governing the monetary and banking system of the
Philippines, such resolutions are not contracts that give rise to obligations which must be fulfilled
by the Central Bank in favor of affected parties. They may be amended or repealed to attain
statutory objectives. Therefore, the Central Bank could not be compelled to resell dollar
earnings at the same preferred rate of exchange i.e., P2.00 per U.S. $1.00) at which they were
surrendered in view of subsequent Central Bank Circulars that such exchange should be sold at
the prevailing market rate.

San Pedro Bus Line vs. Navarro, et al.

G.R. No. L-6291 April 29, 1954

Petitioners: San Pedro Bus Line, Paulino de la Cruz, and Teodoro Lacdan, doing business
under the name of The San Pedro Bus Line
Respondents: Nicolas Navarro, et al.
Ponente: C.J. Paras

Facts: Navarro filed a complaint for damages in the Court of First Instance (CFI) of Rizal
against petitioners due to the physical injuries he sustained while riding a bus of the latter which
collided with another bus. After trial, the court dismissed the complaint. The herein respondents
appealed to the Court of Appeals which reversed the decision of the CFI. The petitioners
contend that they cannot be held civilly liable to Navarro because the CFI had dismissed the
criminal charge against petitioner Paulino de la Cruz, driver of the bus involved in the accident.

Issue: Can the petitioners be held civilly liable even if the accused in the criminal action is
acquitted of the offense charged based on the same act?

Ruling: Yes. The action was not based on tort or quasi delito, but was one for breach of a
carriers contract, there being a clear distinction between culpa as a source and creator of
obligations (aquiliana) and culpa in the performance of an already existing obligation
(contractual).

Cardona vs. NLRC

G.R. No. 89007 March 11, 1991

Petitioners: Juan C. Cardona, representing all former employees of the Commercial Bank &
Trust Company (COMTRUST)
Respondents: The Honorable Labor Relations Commission and The Bank of the Philippine
Islands (BPI)
Ponente: J. Melencio-Herrera

Facts:
Issue:
Ruling:

Cinco vs. Canonoy

Petitioner-appellant: Porfirio P. Cinco

Respondents-appellees: Hon. Mateo Canonoy, et al.
Ponente: J. Melencio-Herrera

Facts:
Issue:
Ruling:

Heirs of Pedro Tayag, Sr. vs. Alcantara

Petitioners: Heirs of Pedro Tayag, Sr.

Respondents: Honorable Fernando S. Alcantara, et al.
Ponente: J. Concepcion Jr.

Facts:
Issue:
Ruling:

Tan vs. Nitafan

Petitioners: Luis Tan, et al.

Respondents: Hon. David G. Nitafan, et al.
Ponente: J. Bellosillo

Facts:
Issue:
Ruling: