II. Quasi-Delict B. No Double Recovery Rule Joseph v.

Bautista Facts: Perez, one of the respondents in the case, is the owner of a car o truc! for conveyin car oes and passen ers. "n a certain day, when said car o truc!, driven by #illa, was on its way to Bulacan, petitioner $oseph boarded the truc! after payin a su% of %oney. &hile said truc! was on the hi hway, #illa tried to overta!e a tricycle. 't about the sa%e ti%e, a pic!up truc!, alle edly owned by respondents (ioson and Pa ari an, and driven by co-respondent #illanueva, tried to overta!e the car o truc! as the latter was on the process of overta!in the tricycle. )his led to the in*ury of $oseph who instituted a co%plaint for da%a es a ainst the owner of the truc! on the round of breach of contract of carria e, and a ainst the owner and driver of the pic!-up truc! on the round of +uasi-delict. )hereafter, respondents #illanueva, ,ardeno, (ioson and Pa ari an, throu h their insurer, paid petitioner-s clai% for in*uries sustained. 's a conse+uence, petitioner e.ecuted a release of clai% in favor of the said payin parties. (ubse+uently, respondent Perez filed a /otion to Dis%iss the case on the pre%ise that the release of clai% e.ecuted by petitioner in favor of the other respondents inured to the benefit of Perez, considerin that all the respondents are solidarily liable to petitioner. )he trial court ranted the %otion and dis%issed the case. 0ence, this petition. Issue: Did the pay%ent by the other respondents inure to the benefit of Perez, sanctionin the dis%issal of the case1 Held: 2es. ' cause of action is understood to be the delict or wron ful act or o%ission co%%itted by the defendant in violation of the pri%ary ri hts of the plaintiff. ' sin le act or o%ission %ay si%ultaneously be violative of various ri hts, as when the act constitutes *uridically a violation of several separate and distinct le al obli ations. Notwithstandin the said fact, where there is only one delict or wron , there is a but a sin le cause of action re ardless of the nu%ber of ri hts that %ay have been violated. If only one in*ury resulted fro% several wron ful acts, only one cause of action arises. In the case at bar, petitioner sustained only one in*ury on his person, vestin in hi% a sin le cause of action, althou h there are correlative ri hts of action a ainst the different respondents throu h the appropriate re%edies allowed. ' recovery by petitioner under one re%edy, as when he already recovered under the principle of

+uasi-delict, necessarily bars recovery under the other. )his is the principle of the proscription in the law a ainst double recovery for the sa%e act or o%ission under the funda%ental rule a ainst un*ust enrich%ent. /oreover, since the respondents are solidarily liable to petitioner, the full pay%ent by so%e of the solidary debtors and their subse+uent release fro% liability resulted in the e.tin uish%ent and release fro% liability of the other solidary debtors, includin Perez.