Case Digest (G.R. No. L-2993)
Facts:
Lucino Almeida Chan Tanco et al. v. Eduardo Abaroa, G.R. No. 2993, March 27, 1907, the Supreme Court, Per Curiam (Arellano, C.J., Torres, Mapa, Willard, and Tracey, JJ., concurring).The plaintiffs (appellants) alleged that the defendant Eduardo Abaroa set fire to and burned their store and camarin (warehouse), destroying goods and effects belonging to them. Because the act constituted the crime of arson, criminal proceedings were instituted against Abaroa (named in the text also as Eduardo Abaroa Chan Em). The criminal tribunal acquitted the accused; that acquittal was in turn affirmed by the Supreme Court on the ground of insufficient proof of participation in the criminal act.
Despite the criminal acquittal, the plaintiffs thereafter pursued a civil action for damages and indemnity against Abaroa based on the same fire. The civil suit was adjudicated below and produced a judgment that was appealed to the Supreme Court. The Court's present decision states additional conclusions in enlargement of and in addition to findings contained in the judgment appealed from and in the Court's own earlier decision rendered in civil cause No. 2993 between these parties.
In this appeal the Supreme Court reviewed whether the civil action could proceed against a person who had been acquitted in criminal proceedings for the act out of which the civil claim arose, and whether the plaintiffs had alleged any distinct civil ground (e.g., negligence) separate ...(Subscriber-Only)
Issues:
- Does a full criminal acquittal bar a subsequent civil action against the same person for civil liability arising from the same act?
- Did the plaintiffs allege a civil cause of action distinct from the criminal act (such as negligence) that would permit civil recovery despite th...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)