### Facts:
Porfirio P. Cinco initiated a complaint in the City Court of Mandaue City, Cebu, Branch II, on February 25, 1970, seeking damages for a vehicular accident involving his car and a jeepney driven by Romeo Hilot and operated by Valeriana and Carlos Pepito — the respondents. Subsequently, a criminal case was filed against Hilot for the same incident. During the civil case’s pre-trial, the respondents moved to suspend the action citing Rule 111, section 3 (b) of the Rules of Court, leading to the City Court’s suspension order on August 11, 1970. Cinco’s motion for reconsideration was denied on August 25, 1970, which led him to elevate the issue to the Court of First Instance of Cebu through a Petition for Certiorari, claiming the City Judge’s suspension was a grave abuse of discretion. This petition was dismissed on November 5, 1970, by the Court of First Instance, a decision upheld through the denial of Cinco’s subsequent motion for reconsideration. Cinco then appealed to the Supreme Court.
### Issues:
1. Whether the civil case for damages based on quasi-delict should be suspended pending the resolution of the criminal case.
2. Appropriateness of Certiorari as a remedy for the aggrieved party.
### Court’s Decision:
The Supreme Court held that the civil action based on quasi-delict can proceed independently and concurrently with the criminal action. The High Court found that the lower court gravely abused its discretion by suspending the civil case, pointing out that the action is predicated on quasi-delict and governed explicitly by Article 2177 of the Civil Code. The Supreme Court underscored the distinction between civil liability arising from crime and that from a quasi-delict, affirming the latter’s independence from criminal proceedings. The petition for certiorari was granted, directing the City Court to proceed with the civil case.
### Doctrine:
This case reiterated the doctrine that a civil action based on a quasi-delict, distinguished from civil liability arising from a criminal offense, can proceed independently of any criminal proceedings. The decision emphasized the autonomy of obligations arising from quasi-delicts as enshrined in Articles 2176 and 2177 of the Civil Code.
### Class Notes:
– **Quasi-delict**: An act or omission causing damage to another due to fault or negligence without pre-existing contractual relations (Civil Code, Article 2176).
– **Independent Civil Actions**: Under Articles 31, 32, 33, 34, and 2177 of the Civil Code, a civil action entirely separate from any criminal procedure can be initiated by the injured party, requiring only a preponderance of evidence (Rules of Court, Rule 111, Section 2).
– **Certiorari as a Remedy**: A legal procedure used to challenge decisions that are alleged to have been made with grave abuse of discretion.
– **Preponderance of Evidence**: The standard of proof used in civil cases, indicating that it is more likely than not that the claim is true.
### Historical Background:
The decision highlights the broader legal and jurisprudential context regarding the distinction between civil liability arising from crimes versus from quasi-delicts, aligning with principles aimed at ensuring the adequate and efficient redress for civil wrongs independent of the criminal justice system’s outcomes.
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