Title
Caina vs. People
Case
G.R. No. 78777
Decision Date
Sep 2, 1992
Acquitted of criminal charges, Caina contested civil liability for damages; Supreme Court ruled no liability due to lack of negligence or recklessness.
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Case Digest (G.R. No. 78777)

Facts:

  1. Criminal Charge and Acquittal:

    • Merlin P. Caina was charged with reckless imprudence resulting in serious physical injuries.
    • The Municipal Trial Court (MTC) of Cagayan de Oro City acquitted him of the criminal charge due to the prosecution's failure to prove his guilt beyond reasonable doubt.
  2. Award of Damages:

    • Despite the acquittal, the MTC ordered Caina to pay the private complainant, Dolores Perez, P2,893.40 as actual damages.
  3. Appeal to the Regional Trial Court (RTC):

    • Caina appealed the award of damages to the RTC, which initially reversed the MTC's decision and absolved him of civil liability.
    • However, upon a motion for reconsideration by the private complainant, the RTC reinstated the MTC's award of damages.
  4. Procedural Errors:

    • Caina filed a notice of appeal to the Supreme Court, claiming a pure question of law, instead of filing a petition for review on certiorari under Rule 45 of the Rules of Court.
    • The RTC forwarded the case to the Court of Appeals, which then transmitted it to the Supreme Court, noting that only questions of law were involved.
  5. Supreme Court's Decision to Review:

    • Despite procedural irregularities, the Supreme Court decided to review the case due to its importance and the fact that the records had already been brought before it.

Issue:

  1. Whether the trial court and the RTC erred in awarding civil liability against Caina despite his acquittal.
  2. Whether the award of damages is void and illegal due to the absence of a finding of preponderance of evidence establishing a causal connection between the facts and the damage suffered by the private complainant.

Ruling:

The Supreme Court granted the petition and set aside the RTC's order reinstating the award of damages. The Court reinstated the RTC's initial decision absolving Caina of civil liability.

Ratio:

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