Civil Liability Arising From A Crime
Civil Liability Arising From A Crime
Civil Liability Arising From A Crime
• Art. 1161 Civil Obligations arising from criminal offenses shall be governed by the penal
laws, subject to the provisions of article 2177, and of the pertinent provisions of Chapter
2, Preliminary Title, on Human Relations, and of Title XVIII of this book, regulating
damages.
Civil liability arising from crimes or delicts.
• This article deals with civil liability arising from crimes or delicts.
(1) The commission of an offense has a two-pronged effect: one, on the public as it
breaches the social order and the other, upon the private victim as it causes personal
sufferings or injury, each of which is addressed, respectively, by the imposition of
heavier punishment on the accused and by an award of additional damages to the
victim. (People vs. Catubig, 363 SCRA 621 [2001].)
12 Art. 2143. The provisions for quasi-contracts in this Chapter do not exclude other
qua-
si-contracts which may come within the purview of the preceding article. (n)
13 Quantum meruit allows recovery of the reasonable value regardless of any
agreement
as to value. It entitles the party to “as much as he reasonably deserves,’’ as distinguished from
quantum valebant or to “as much as what is reasonably worth.’’ Recovery based on quantum
meruit presents a justiciable question because its settlement requires the application of
judgment and discretion and cannot be adjusted by simple arithmetical processes. (F.F.
Mañacop Construction Co., Inc. vs. Court of Appeals, 266 SCRA 235 [1997].) The doctrine of
quantum meruit prevents undue enrichment based on the equitable postulate that it is unjust for
a person to retain benefit without paying for it. (Philippine National Bank vs. Shellink Planners,
Inc., 473 SCRA 552 [2006].)
14 The pertinent provisions are Articles 100 to 113 of the Revised Penal Code.
15 Art. 2177. Responsibility for fault or negligence under the preceding article [Art.
2176,
Note 19.] is entirely separate and distinct from the civil liability arising from negligence under the
Penal Code. But the plaintiff cannot recover damages twice for the same act or omission of the
defendant. (n)
16 Among the pertinent provisions are Articles 29 to 35 of the Civil Code.
(2) Oftentimes, the commission of a crime causes not only moral evil but also material
damage. From this principle, the rule has been established that every person criminally liable for
a felony17 is also civilly liable. (Art. 100, Revised Penal Code; see Albert, the Revised Penal
Code Annotated, p. 276.) In crimes, however, which cause no material damage (like contempt,
insults to person in authority, gambling, violations of traffic regulations, etc.), there is no civil
liability to be enforced. But a person not criminally responsible may still be liable civilly. (Art. 29;
Rules of Court, Rule 111, Sec. 2[c].)