PEDRO ELCANO and PATRICIA ELCANO, in their capacity as Ascendants of Agapito Elcano,

deceased
vs.
REGINALD HILL, minor, and MARVIN HILL, as father and Natural Guardian of said minor

G.R. No. L-24803 May 26, 1977

Torts and Damages – Civil Liability from Quasi Delicts vs Civil Liability from Crimes

FACTS:

Reginald Hill, a minor, caused the death of Agapito (son of Elcano). Elcano filed a criminal
case against Reginald but Reginald was acquitted for “lack of intent coupled with mistake.” Elcano
then filed a civil action against Reginald and his dad (Marvin Hill) for damages on the ground that the
act constitutes culpa aquiliana and on the part of Reginalds father, based on on the vicarious liability
of parents under Article 2180 of the Civil Code.

Hill argued that the civil action is barred by his son’s acquittal in the criminal case; and that if
ever, his civil liability as a parent has been extinguished by the fact that his son is already an
emancipated minor by reason of his marriage.

ISSUE/S:

Whether the civil liability is barred by the acquittal of Reginald in the Criminal Case. – NO.

RULING:

No. The acquittal of Reginald in the criminal case does not bar the filing of a separate civil
action. In the present case, the Supreme Court ruled that the extinction of civil liability referred to in
Section 3, Rule 111, of the Rules of Court, refers exclusively to civil liability founded on Art. 100 of
the Revise Penal Code, whereas the civil liability for the same act considered as a quasi-delict only
and not as a crime is not extinguished even by a declaration in the criminal case that the criminal act
charged has not happened or has not been committed by the accused. Briefly stated, culpa
aquiliana or quasi-delict includes voluntary and negligent acts which may be punishable by law.