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HEIRS OF THE LATE TEODORO GUARING JR., might arise did not exist.

Thus, the civil liability is


plaintiff vs. COURT OF APPEALS, defendant not extinguished by acquittal where the acquittal is
G.R. No. 108395. March 7, 1997 based on reasonable doubt as only preponderance
of evidence is required in civil cases; where the
FACTS: court expressly declares that the liability of the
accused is not criminal but only civil in nature as,
On November 7, 1987, the car driven by Teodoro for instance, in the felonies of estafa, theft, and
Guaring Jr. collided with the Philippine Rabbit Bus malicious mischief committed by certain relatives
driven by Angelo Cuevas and wth a who thereby incur only civil liability; and, where
Toyota Cressida Car driven by Eligio Enriquez, along the civil liability does not arise from or is not based
the North Luzon Expressway in San Rafael, Mexico upon the criminal act of which the accused was
Pampanga.. As a consequence, Guaring died. acquitted.

The trial court ruled in favor of herein petitioners, Therefore, the Supreme Court ruled that the
but lost in the Court of Appealswhere the accused proceedings for the civil case of the
was acquitted based on reasonable doubt. This was said incident must continue for the recovery of
because it was found out that the deceased was damages of the victim’s heirs. The case was
the one who acted negligently. The accused the remanded to the trial court to determine the civil
claimed appealed in the court that the civil case liability of the accused.
filed against him be extinguished since the
extinguishment of his criminal liability necessarily
follows the extinguishment of his civil liability, since
his civil liability aroused from his criminal liability.
The petitioners disagreed on this ground, claiming
that the civil case should pursue. This was then
appealed to the Supreme Court.

ISSUE:

Whether or not the civil case must be terminated


as a consequence of the termination of the criminal
case based on reasonable doubt.

RULING:

The Supreme Court held that the acquittal of the


bus driver was based on reasonable doubt, which
means that the civil case for damages was not
barred since the cause of action of the heirs was
based on quasi delict. Even if damages are sought
on the basis of crime and not quasi delict, the
acquittal of the bus driver will not bar recovery of
damages because the acquittal was based not on a
finding that he was not guilty but only on
reasonable doubt. Thus, it has been held:

The judgment of acquittal extinguishes the liability


of the accused for damages only when it includes a
declaration that the facts from which the civil

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