Case Digest (G.R. No. 76233)
Facts:
Zayda S. Biscocho v. People of the Philippines, G.R. No. 76233, January 15, 1988, the Supreme Court En Banc, Padilla, J., writing for the Court.
Petitioner Zayda S. Biscocho, then Municipal Development Coordinator and Head of the Planning and Development Staff of Pola, Oriental Mindoro, was criminally charged before the Sandiganbayan in Criminal Case No. 9252 with violation of Section 3(e) of Republic Act No. 3019, in an information filed 28 June 1984 alleging that on or about 25 June 1982 she recommended construction of a barrio road that traversed the complainant’s land, misrepresented ownership of adjacent land, allowed construction to proceed and thereby caused P30,000 in damages by cutting fruit trees.
After trial the Sandiganbayan rendered judgment (dated 21 May 1986, promulgated 17 June 1986) acquitting petitioner of the crime for failure of the prosecution to prove guilt beyond reasonable doubt, but nonetheless ordering petitioner to pay the complainant Leonida Biscocho P30,000.00 as actual damages; the court reasoned that although acquitted, petitioner was civilly liable for the unauthorized construction over complainant’s land.
Petitioner moved for partial reconsideration on 2 July 1986 seeking deletion of the damages award; the Sandiganbayan denied the motion on 3 October 1986. Petitioner then filed the present petition with the Supreme Court challenging the imposition of civil liability, alleging the Sandiganbayan acted without or in excess of jurisdiction and with grave abuse of discretion in ordering payment of actual damages.
The Sandiganbayan itself had found petitioner’s duties were limited to planning and recommendation of municipal development projects and that implementation, including approval and location of roads, was the responsibility of the Bureau of Public Highways (BPH) eng...(Pro-only)
Issues:
- Did the Sandiganbayan act without jurisdiction or in excess of jurisdiction, or with grave abuse of discretion, in ordering petitioner to pay actual damages after acquittal?
- Was there sufficient evidence to hold petitioner civilly liable for the damages resulting from the constructi...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)