Eclectic Theory of Criminal Law

Melba Quinto vs. Dante Andres and Randyver Pacheco

[G.R. NO. 155791, March 16, 2005]

Title of the Case Melba Quinto, Petitioner, v. Dante Andres and Randyver
Pacheco, Respondents.
When promulgated 16 March 2005
Parties Melba Quinto, mother of victim Wilson Quinto - petitioner
Dante Andres – respondent / accused
Randyver Pacheco – respondent / accused
Brief Background / story -Eleven year-olds Edison Garcia and Wilson Quinto were
invited by the two respondents, Dante Andres and Randyver
Pacheco to go fishing inside the drainage culvert but it was
only Wilson Quinto who joined them because Edison Garcia
saw it was dark inside and opted to sit two meters away.
- Later on, Pacheco emerged and fled the scene while
Andres came out carrying the dead body of Quinto, Andres
then informed the latter’s mother that her son has died.
- No autopsy was conducted on Quinto’s body. Tarlac police
authorities did not file a complaint against the respondents.
- NBI took the sworn statements of the respondents and
petitioner then exhumed the body of Wilson Quinto for
autopsy performed by Dr. Dominic Aguda. Postmortem
findings showed that the cause of death was asphyxia with
drowning and traumatic head injuries as contributory.
- NBI filed criminal complaint against the respondents which
the Office of the Provincial Prosecutor has found probable
cause for homicide by dolo (malice).
- Information or the case was filed in RTC Tarlac, Tarlac.
- After the prosecution rested its case, respondents filed a
demurrer to evidence which the trial court granted on the
ground of insufficiency of evidence making them not liable
for any civil damages.
- Petitioner appealed the order to the Court of Appeals
insofar as the civil aspect of the case. CA affirmed the order
of the RTC.
- Petitioner filed an Instant Petition to Review to the SC but
was denied due to lack of merit. No costs
Claims of People / Respondents are liable for criminal and civil damages for
complainant Quinto’s death
Claims of accused No preponderant evidence on record to justify their civil
liability
Relevant issue 1.Whether or not the extinction of the respondents’ liability,
likewise, carries with it the extinction of their civil liability
2. Whether or not preponderant evidence exists to hold
them civilly liable for Wilson’s death
Ruling of lower court RTC – Acquitted
CA – Affirmed
Ruling of SC Denied the petition for lack of merit
Reasoning No preponderant evidence exists to hold them liable for
damages
Relevant doctrine from the Eclectic or Mixed theory
case Every person criminally liable for a felony is also civilly
liable. The civil liability of such person established in Articles
100, 102 and 103 of the Revised Penal Code includes
restitution, reparation of the damage caused, and
indemnification for consequential damages. When a criminal
action is instituted, the civil action for the recovery of civil
liability arising from the offense charged shall be deemed
instituted with it. With the implied institution of the civil action
in the criminal action, the two actions are merged into one
composite proceeding, with the criminal action
predominating the civil.

The prime purpose of the criminal action is to punish the

offender in order to deter him and others from committing
the same or similar offense, to isolate him from society
(Classical Theory), and/or to reform and rehabilitate him
(Positivist Theory.)

The sole purpose of the civil action is the indemnification of

the private offended party for the damage or injury he
sustained by reason of the delictual or felonious act of the
accused. Extinction of the penal action does not carry with
the extinction of the civil action. However, civil action based
on delict shall be deemed extinguished if there is a finding in
the final judgment in the criminal action that the act or
omission does not exist.

A person committing a felony is criminally liable for all the

natural and logical consequences resulting therefrom
although the wrongful act done be different from that which
he intended. Proximate cause is that cause which in natural
and continuous sequence, unbroken by an efficient
intervening cause, produces the injury, and without which
the result would not have occurred. There must be a relation
of "cause and effect," the cause being the felonious act of
the offender, the effect being the resultant injuries and/or
death of the victim.