Manantan v CA
Jan 29, 2001
J. Quisumbing
FACTS
- June 1, 1983, an info was filed charging Manantan with
reckless imprudence resulting to damage to property
(sideswiped a jeepney owned by Charles Codamon) and
death (Ruben Nicolas, passenger of the jeep) which
happened at Daang Maharlika
- It was alleged in the evidence presented by the prosecution
that Manantan was intoxicated, after going on a drinking
spree just before the accident happened; where the car
driven by Manantan, going at a speed of 40kph (80-90
according to Charles Cudamon) tried to overtake a tricycle,
but instead hit an oncoming jeepney
- The defense alleged the same except that Manantan did not
drink prior to the accident
- RTC found Manantan not guilty
- On appeal, Nicolas spouses prayed that the decision be
modified and that appellee be ordered to pay indemnity and
damages
- CA ruled in favor of the Nicolas Spouses
- CA noted that at the time of the accident, Manantan was
intoxicated, due to his having consumed all in all, a total of at
least twelve (12) bottles of beer between 9 a.m. and 11 p.m
- This act of driving while intoxicated was a clear violation of
Section 53 of the Land Transportation and Traffic Code (R.A.
No. 4136)[7] and pursuant to Article 2185 of the Civil
Code,[8] a statutory presumption of negligence existed
- Petitioner filed an MR but was denied
ISSUE and RULING
WON acquittal of petitioner foreclose any further inquiry by the CA
as his reckless imprudence
NO. There was no second jeopardy as the subject of the appeal is only
the civil aspect of the criminal case (they only filed for appeal on the
indemnity and damages).
For double jeopardy to exist, the following elements must be
established: (a) a first jeopardy must have attached prior to the
second; (2) the first jeopardy must have terminated; and (3) the
second jeopardy must be for the same offense as the first.
WON CA erred in finding that petitioner’s acquittal did not extinguish
his civil liability
NO. The acquittal was based on reasonable doubt; hence, petitioners
civil liability was not extinguished by his discharge.
Two kinds of acquittal:
1. acquittal on the ground that the accused is not the author of
the act or omission complained of (Rule 111 ROC)
a. Person who has been found to be not the
perpetrator of any act or omission cannot and can
never be held liable for such act or omission
2. acquittal based on reasonable doubt on the guilt of the
accused (Article 29 NCC)
a. If the guilt of the accused has not been satisfactorily
established, he is not exempt from civil liability which
may be proved by preponderance of evidence only
The decision of the trial courts was based on the second kind of
acquittal. The trial courts declaration that did not discount the
possibility that the accused was really negligent.
WON CA committed a reversible error in failing to apply the
Manchester Doctrine
NO.

Manchester Doctrine: the Court acquires jurisdiction over any case

only upon payment of the prescribed docket fees

Rule 111 of the 1985 Rules of Criminal Procedure (applicable during

the pendency of the case) states however that where the civil action
is impliedly instituted together with the criminal action, the actual
damages claimed by the offended parties, as in this case, are not
included in the computation of the filing fees