The preponderance of evidence standard applies primarily to civil law cases.

For
example, if Linda sues Tom due to injuries she sustained in a car crash, Linda
must convince the courts that it is more probable than not that Tom caused the
crash resulting in her injuries.

4)     Mauricio Manliclic vs. Modesto Calaunan, G.R. No. 150157, January 25, 2007 (negligence)

FACTS:

1. The front right side of the Philipine Rabbit Bus owned by PRBLI and driven by petitioner
Mauricio Manliclic, hit the rear side of the of the owner-type jeep owned by respondent
Modesto Calaunan, and driven by Marcelo Mendoza, causing the respondent suffered minor
injuries while his driver was unhurt.

2. By reason of such collision a criminal case was filed before the RTC of Bulacan against
petitoner Manliclic with Reckless Imprudence Resulting in Damge to Property with Physical
Injuries.Also, respondent filed a civil case for damages against petitoners Manliclic before the
RTC of Dagupan City.

3. Petitioners contented that the jeep overtook the Philippine Rabbit Bus, meaning they
stopped in front of the bus and testified that the jeep owned by respondent swerved to the
right because it was bumped by the Philippine Rabbit Bus from behind.

4. Petitioner PRBLI maintained that it observed and exercised the diligence of a good father of a
family in the selection and supervision of its employee, specifically petitioner Manliclic.

5. The Trial Court and Court of Appeals rendered its decision in favor of the respondent
Calaunan.

6. Hence, this petition.

ISSUE:

WON Maliclic’s acquittal in the criminal case finding him not negligent may acquit him from
civil liability?

RULING:

From the declaration of the Court of Appeals that acquited petitioner Manliclic not on
reasonable doubt but on the ground that he is not the author of the act complained of which is
based on Section 2 (b) of Rule 111 of the Rules of Criminal Procedure. However, petitioner
Manliclic can still be held liable for the mishap. The afore-mentioned section applies only to a
civil action arising from crime or ex delicto and not to a civil action arising from quasi-delict or
culpa aquiliana.

The extinction of civil liability referred to in Par. (e) of Section 3, Rule 111 [now Section 2 (b) of
Rule 111], refers exclusively to civil liability founded on Article 100 of the Revised Penal Code,
whereas the civil liability for the same act considered as a quasi-delict only and not as a crime is
not extinguished even by a declaration in the criminal case that the criminal act charged has not
happened or has not been committed by the accused.

A quasi-delict or culpa aquiliana is a separate legal institution under the Civil Code with a
substantivity all its own, and individuality that is entirely apart and independent from a delict or
crime—a distinction exists between the civil liability arising from a crime and the responsibility
for quasi-delicts or culpa extra-contractual. The same negligence causing damages may produce
civil liability arising from a crime under the Penal Code, or create an action for quasi-delicts or
culpa extra-contractual under the Civil Code.34 It is now settled that acquittal of the accused,
even if based on a finding that he is not guilty, does not carry with it the extinction of the civil
liability based on quasi delict.

WHEREFORE, premises considered, the instant petition for review is DENIED. The decision of
the Court of Appeals in CA-G.R. CV No. 55909 is AFFIRMED with the MODIFICATION that (1) the
award of moral damages shall be reduced to P50,000.00; and (2) the award of exemplary
damages shall be lowered to P50,000.00. Costs against petitioners.

5)          Faustino Barredo vs. Severino Garcia and Timotea Almario, G.R. No. L-48006, July 8,
1942 (quasi-delict)

FACTS:
1. On May 3, 1936 there was a head-on collision between a taxi of the Malate Taxicab driven by
Pedro Fontanilla and carretela guided by Pedro Dimapalis that caused Faustino Garcia’s
suffered injuries from which the latter died two days later. Fontanilla’s negligence was the cause
of the mishap, as he was driving on the wrong side of the road, and at high speed.
2. A criminal action was filed against Fontanilla, a taxi driver employed by the petitioner, in the
Court of First Instance of Rizal and he was convicted and sentenced to an indeterminate
sentence of one year and one day to two years of prision correccional.
3. Respondents, parents of the deceased brought an action in the Court of First Instance of
Manila against Fausto Barredo as the sole proprietor of the Malate Taxicab and employer of
Pedro Fontanilla.
4. The Court of Appeals holds that the petitioner is being sued for his failure to exercise all the
diligence of a good father of a family in the selection and supervision of Pedro Fontanilla to
prevent damages suffered by the respondents.
5. The Court of Appeal insists on applying in the case article 1903 of the Civil Code, in the
precise words of said article, is applicable only to “those (obligations) arising from wrongful or
negligent acts or commission not punishable by law.
6. Petitioner contended that his liability was governed by the Revised Penal Code, and his
responsibility was only secondary; but no civil action had been brought against the taxi driver.
ISSUE:
Whether or not that the respondents may bring this separate civil action against petitioner, thus
making him primarily and directly, responsible under article 1903 of the Civil Code as an
employer of Pedro Fontanilla?
RULING:
The Supreme Court held that this separate civil action lies, the employer being primarily and
directly responsible in damages under articles 1902 and 1903 of the Civil Code. In this
jurisdiction, the separate individuality of a cuasi-delito or culpa aquiliana under the Civil Code,
has been fully and clearly recognized, even with regard to a negligent act for, which the
wrongdoer could have been prosecuted and convicted in a criminal case and for which, after
such a conviction, he could have been sued for his civil liability arising from his crime.
A quasi-delict or "culpa aquiliana" is a separate legal institution under the Civil Code, with a
substantivity all its own, and individuality that is entirely apart and independent from a delict or
crime. Upon this principle, and on the wording and spirit of article 1903 of the Civil Code, the
primary and direct responsibility of employers may be safely anchored.
In view of the foregoing, the judgment of, the Court of Appeals should be and is hereby affirmed,
with costs against the defendant-petitoner.

6)          Edgardo Mendoza vs. Abundio Arrieta, G.R. No. L-32599, June 29, 1979, (quasi-delict,
independent civil actions)
7)          Jose Amadora vs. Court of Appeals and Colegio De San Jose-Recoletos, G.R. No. L-
47745, April 15, 1988 (contract, negligence, in loco parentis)