Crim Pro Digest: Casupanan v. Laroya (GR No. 145391)
Criminal Procedure, Digest focusing on Rule 111: Prosecution of Civil Actions, When Civil Action May Proceed Independently G. R. No. 145391 August 26, 2002 Avelino Casupanan and Roberto Capitulo , petitioners, v. Mario Llavore Laroya, respondent. Carpio, J. : FACTS: Two vehicles, one driven by respondent Laroya and the other owned by petitioner Capitulo and driven by petitioner Casupanan, figured in an accident. This prompted the filing of two cases before the MCTC of Capas Tarlac: 1st – a criminal case for reckless imprudence resulting to damage to property filed by respondent against Casapunan; 2nd – a civil case arising from a quasi-delict filed by the petitioners against the respondent. The civil case was filed pending preliminary investigation on the criminal case. Respondent as defendant in the civil case filed a motion to dismiss on ground of forum shopping due pendency of the criminal case. The MCTC gr...