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Title
Philippine Rabbit Bus Lines, Inc. v. People

Case Ponente Decision Date

G.R. No. 147703 PANGANIBAN, J : 2004-04-14

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Facts
This case involves a petition for review filed by Philippine Rabbit Bus Lines, Inc. (petitioner) against the
People of the Philippines (respondent). The petitioner appealed the judgment of the Regional Trial Court
(RTC) of San Fernando, La Union in Criminal Case No. 2535, which found the accused-employee guilty of
reckless imprudence resulting in triple homicide, multiple physical injuries, and damage to property. The
accused-employee was sentenced to imprisonment and ordered to pay damages to the victims and their
families.

Issue
The main issue in this case is whether the employer, who participated in the defense of its accused-
employee, may appeal the judgment of conviction independently of the accused.

Ruling
The Supreme Court ruled that both the accused and the prosecution have the right to appeal a criminal
case, but the government can only do so if it does not place the accused in double jeopardy. The offended
parties also have the right to appeal the judgment with respect to their civil liability. However, if the accused
jumps bail, the appellate court may dismiss the appeal. In this case, the accused-employee had jumped
bail, and his appeal was dismissed. Therefore, the judgment against him became final and executory.

Ratio
The Court clarified that the civil liability of the accused arising from the crime charged is deemed instituted
in a criminal action, unless the offended party waives the civil action, reserves the right to institute it
separately, or institutes it prior to the criminal action. The employer's subsidiary civil liability can be
enforced through execution based on the judgment of conviction.

The court also stated that the employer's liability in a criminal case is subsidiary, and they are not
considered direct parties to the case. While they may assist their employees in their defense, they cannot
act independently on their own behalf. By jumping bail, the accused-employee effectively waived his right
to appeal, and his conviction became final and executory. The court emphasized that the right to appeal is
not a natural right or part of due process, but a procedural remedy that must be strictly complied with.

Furthermore, the court clarified that the subsidiary liability of the employer accrues upon the finality of the
judgment against the employee. The employer's liability is dependent on the employee's civil liability, and it
cannot be separated from it. The court also emphasized that the employer's liability is contingent on the
fulfillment of certain requirements, such as proving the employer-employee relationship, the employee's
engagement in some kind of industry, and the employee's commission of the offense in the discharge of his
:
 duties.

Summary
This case involves the subsidiary liability of an employer in a criminal case filed against its employee. The
petitioner, a bus company, appealed the decision of the trial court finding its employee guilty of a crime.
The Court of Appeals dismissed the appeal, stating that the petitioner has no right to appeal as it is not a
direct party to the criminal case. The petitioner argued that it should be allowed to appeal because it
participated in the defense of its employee.

The Supreme Court ruled that the petitioner does not have the right to appeal. It explained that the
employer's liability in a criminal case is subsidiary, and they are not considered direct parties to the case.
While they may assist their employees in their defense, they cannot act independently on their own behalf.

The court also stated that by jumping bail, the accused-employee effectively waived his right to appeal,
and his conviction became final and executory. The court emphasized that the right to appeal is not a
natural right or part of due process, but a procedural remedy that must be strictly complied with.

Furthermore, the court clarified that the subsidiary liability of the employer accrues upon the finality of the
judgment against the employee. The employer's liability is dependent on the employee's civil liability, and it
cannot be separated from it. The court also emphasized that the employer's liability is contingent on the
fulfillment of certain requirements, such as proving the employer-employee relationship, the employee's
engagement in some kind of industry, and the employee's commission of the offense in the discharge of his
duties.

In conclusion, the court denied the petitioner's appeal and affirmed the decision of the Court of Appeals.
The court clarified that the petitioner does not have the right to appeal the criminal case against its
employee, and the subsidiary liability of the petitioner now accrues. The court also emphasized that the
right to appeal is not a natural right or part of due process, and strict compliance with the procedural
requirements is necessary.

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