Casupanan vs Laroya, 388 SCRA 28

Casupanan v. Laroya
388 SCRA 28

Facts:
Two vehicles, one driven by respondent Laroya and the other owned by petitioner Capitulo and driven by petitioner Casupanan, figured in an accident. As a result, two cases were filed with the Municipal Circuit Trial Court of Capas, Tarlac. Laroya filed a criminal case against Casupanan for reckless imprudence resulting in damage to property, while Casupanan and Capitulo filed a civil case against Laroya for quasi-delict.

Issue:
Whether or not  an accused in a pending criminal case for reckless imprudence can validly file, simultaneously and independently, a separate civil action for quasi-delict against the private complainant in the criminal case.

​Held:
Yes. The accused can file a civil action for quasi-delict for the same act or omission he is accused of in the criminal case. This is expressly allowed in paragraph 6, Section 1 of the present Rule 111 which states that any cause of action which could have been the subject of the offense may be litigated in a separate civil action. In this case, the counterclaim of the accused shall be litigated in a separate civil action