Practice question
An agency argues that a guard's criminal conviction necessarily makes every separate civil claim against the agency only subsidiary under the Penal Code, even where the complaint properly asserts quasi-delict. Which case rejects that automatic reclassification?
- Safeguard Security Agency v. Tangco
- A rule making complaint allegations irrelevant
- A rule that every conviction cancels civil duties
- A rule that employers always receive immunity
- A rule abolishing Article 2180
Legal references
- Civil Code Articles 2176–2177, 2180 and 2194: https://lawphil.net/statutes/repacts/ra1949/ra_386_1949.html
- Elcano v. Hill, GR L-24803, May 26, 1977, main decision, scope of culpa aquiliana: https://lawphil.net/judjuris/juri1977/may1977/gr_24803_1977.html
- Safeguard Security Agency v. Tangco, GR 165732, December 14, 2006, main decision: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/40427
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