Title
Billedo vs. Wagan
Case
G.R. No. 175091
Decision Date
Jul 13, 2011
Complainants arrested for public drinking filed a civil case for damages against police officers, alleging unlawful arrest. Criminal complaints were dismissed, but civil case proceeded as no criminal action was filed, making R.A. No. 8249 inapplicable. Supreme Court upheld RTC jurisdiction.
Font Size:

Case Digest (G.R. No. 175091)

Facts:

  1. Arrest Incident:
    On February 27, 2000, complainants Alberto Mina, Nilo Jay Mina, and Ferdinand Caasi were arrested by petitioners (police officers) for allegedly drinking liquor in a public place along an alley in Pasay City. The arrest was based on a report by Ferdinand Cruz and Mariano Cruz (the Cruzes). The complainants claimed the arrest was unlawful and induced by the Cruzes.

  2. Criminal Charges:
    The complainants were charged with violating City Ordinance No. 265 (Drinking Liquor in Public Places) in Criminal Case No. 00-621 before the Metropolitan Trial Court (MeTC) of Pasay City.

  3. Civil Case for Damages:
    On March 20, 2000, the complainants filed Civil Case No. 00-0089 against the petitioners for damages arising from the alleged unlawful arrest.

  4. Criminal Complaints Against Petitioners:
    Complainants also filed criminal complaints against the petitioners for Unlawful Arrest and Violation of R.A. No. 7438 (Rights of Persons Under Custodial Investigation) before the City Prosecution Office (CPO) and the Office of the Ombudsman. Both offices dismissed the complaints for lack of probable cause, but the Ombudsman recommended filing charges for Violation of Section 3(e) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act) against some petitioners.

  5. Dismissal of Criminal Cases:
    The CPO dismissed the criminal cases for lack of merit, noting that the Cruzes’ report had a semblance of truth, and the arrest was lawful. The complainants were later convicted by the MeTC for violating City Ordinance No. 265, which was affirmed by the RTC.

  6. Motion to Dismiss Civil Case:
    During the trial of Civil Case No. 00-0089, petitioner Ferdinand Cruz filed a Motion to Dismiss, arguing that the Sandiganbayan, not the RTC, had jurisdiction over the civil case, and that the complainants were barred from filing a separate civil action under Section 4 of R.A. No. 8249 (Sandiganbayan Act).

  7. Denial of Motion to Dismiss:
    The public respondent (Judge Wilhelmina Wagan) denied the Motion to Dismiss, ruling that the crime of unlawful arrest falls under the jurisdiction of the MeTC, not the Sandiganbayan. She also noted that no criminal case for unlawful arrest was filed, making Section 4 of R.A. No. 8249 inapplicable.

  8. Subsequent Motions and Denials:
    Ferdinand Cruz filed a Motion for Reconsideration and a Second Motion for Reconsideration, both of which were denied by the public respondent.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Jurisdiction of Civil Cases:
    Civil actions for damages arising from alleged unlawful acts are distinct from criminal actions. The dismissal of criminal charges does not automatically extinguish the civil liability unless the court declares that the facts giving rise to the civil liability did not exist.

  2. Application of R.A. No. 8249:
    Section 4 of R.A. No. 8249 applies only when a criminal action is filed before the Sandiganbayan or appropriate courts. Since no criminal action was filed in this case, the RTC properly exercised jurisdiction over the civil case.

  3. Preponderance of Evidence in Civil Cases:
    Even if the criminal charges were dismissed, the complainants can still pursue the civil case by proving their claims through preponderance of evidence.

  4. Interlocutory Orders:
    Orders denying motions to dismiss are interlocutory and not appealable. The proper remedy is to await the final judgment and raise the issue on appeal.


Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.