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Manlangit vs. Urgel

1) A jeepney owned by the complainant and driven by Edgardo Castillo was involved in an accident where it swerved off the road and plunged into a river while navigating a blind curve to avoid a parked dump truck. Passengers sustained injuries. 2) A criminal complaint was filed against the driver Castillo and the complainant jeepney owner before respondent judge, who then issued arrest warrants for both. 3) The Supreme Court ruled the complainant jeepney owner could not be held criminally liable for the driver's negligence, as an employer is only subsidiary civilly liable unless they participate in, counsel, or abet the criminal acts of their employee. The judge erroneously issued

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90 views1 page

Manlangit vs. Urgel

1) A jeepney owned by the complainant and driven by Edgardo Castillo was involved in an accident where it swerved off the road and plunged into a river while navigating a blind curve to avoid a parked dump truck. Passengers sustained injuries. 2) A criminal complaint was filed against the driver Castillo and the complainant jeepney owner before respondent judge, who then issued arrest warrants for both. 3) The Supreme Court ruled the complainant jeepney owner could not be held criminally liable for the driver's negligence, as an employer is only subsidiary civilly liable unless they participate in, counsel, or abet the criminal acts of their employee. The judge erroneously issued

Uploaded by

Ainah Sales
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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REYNATO MANLANGIT vs. JUDGE MELITO L.

URGEL
250 SCRA 560

FACTS:

On August 13, 1994, the jeepney owned by complainant and driven by Edgardo Castillo, plied its
usual route going to Virac, Catanduanes. While approaching a blind curve, the jeepney driver occupied
the wrong lane. At the curve, they suddenly saw a parked dump truck and in order to avoid collision
driver swerved to the right and accidentally plunged into the river. The passengers sustained some
injuries.
Consequently, a criminal complaint against Castillo and complainant was filed before the sala of
respondent judge who then issued a warrant for the arrest of both Castillo and complainant.

ISSUE:

Whether or not complainant can be held criminally liable.

RULING:

It is a basic postulate in criminal law that the criminal act of one person cannot be charged to
another without a showing that the other participated directly or constructively in the act or that
the act was done in furtherance of a common design or purpose for which the parties were united in
intention. In cases of employer-employee relations, an employer is not criminally liable for the
criminal acts of his employee or agent unless he, in some way, participates in, counsels or abets his
employee's acts or omissions. In such case, the employer himself becomes a participant to the criminal
act of his employee. His liability under the circumstances is direct and criminal. However, under
Article 102, in relation to Article 103 of the Revised Penal Code, the employer's liability for the
criminal negligence of his employee is subsidiary in nature and is limited only to civil indemnity.
Thus, an employer is party to a criminal case for the criminal negligence of his employee only by reason
of his subsidiary civil liability under the law. In the case at bar, nowhere does it show that
complainant/jeepney owner participated in, abetted or even approved the negligent and reckless manner in
which his driver maneuvered the vehicle on that blind curve. The judge erroneously issued a warrant of
arrest against the complainant.

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