Practice question
A claimant obtains satisfaction of the full damages for one injury in a criminal case, then demands payment of the same damages again on a favorable quasi-delict judgment. Is the second recovery allowed?
- Yes, different judgments always mean separate compensation.
- Yes, if different lawyers handled the cases.
- Yes, because quasi-delict is independent.
- No; independence does not permit recovery twice for the same act or omission.
- No civil recovery is possible in either case.
Legal references
- https://lawphil.net/courts/rules/rc_110-127_crim.html — Rule 111 sections 1–3: ex delicto action and independent civil actions.
- https://lawphil.net/statutes/repacts/ra1949/ra_386_1949.html — Civil Code articles 32, 33, 34, 2176 and 2177.
- https://lawphil.net/judjuris/juri2002/aug2002/gr_145391_2002.html — Casupanan v. Laroya, G.R. 145391, August 26, 2002, main opinion: no reservation and independent quasi-delict.
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