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Facts
Daluraya was the alleged driver of a Nissan Vanette who ran over Oliva resulting to her death. He was charged in an Information
for Reckless Imprudence Resulting in Homicide in connection with the death of Marina Oliva (mother of the respondent).
MeTC dismissed the case for insufficiency of evidence. RTC Affirmed MeTCs decision.
CA held that the MeTCs decision showed that the Acquittal of Daluraya was based on the fact that prosecution failed to prove
his guilt beyond reasonable doubt hence, Daluraya was not exonerated from his civil liability.
Issue: Whether or not Daluraya is civilly liable for Olivas death despite his acquittal in the criminal case
Ruling : No. SC ruled that CA erred in construing MeTCs findings (decision was affirmed by RTC) that Dalurayas acquittal was
anchored on reasonable doubt. Based on the records, Dalurayas acquittal was based on the fact that "the act or omission from
which the civil liability may arise did not exist in view of the failure of the prosecution to sufficiently establish that he was the
author of the crime ascribed against him. By the nature* of the acquittal it is deemed as non-existent.
*Every person criminally liable for a felony is also civilly liable. The acquittal of the accused does not necessarily extinguish his
civil liability.
1. An acquittal on the ground that the accused is not the author of the actor omission complained of, there being no civil
liability. If there is a civil action it must be based on grounds different from the delict complained of.
2. An acquittal based on reasonable doubt on the guilt of the accused. Not Exempt from Criminal Liability.