Case Digest (G.R. No. 78777)
Facts:
The case involves Merlin P. Caina, the petitioner, who was accused of reckless imprudence resulting in serious physical injuries. The events leading to the case occurred in Cagayan de Oro City, where the Municipal Trial Court, Branch 4, rendered a decision on February 17, 1986, acquitting Caina of the criminal charge. However, the court ordered him to pay Dolores Perez, the private complainant, the amount of P2,893.40 as actual damages. The trial court's decision stated that the prosecution failed to establish Caina's guilt beyond a reasonable doubt, but it still imposed civil liability for damages incurred by Perez. Caina appealed this civil aspect to the Regional Trial Court of Misamis Oriental, Branch 24, which initially reversed the trial court's decision, absolving Caina of civil liability. However, upon a motion for reconsideration filed by Perez, the Regional Trial Court reinstated the original award of damages. Caina subsequently filed an appeal, questioni...
Case Digest (G.R. No. 78777)
Facts:
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.
Award of Damages:
- Despite the acquittal, the MTC ordered Caina to pay the private complainant, Dolores Perez, P2,893.40 as actual damages.
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.
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.
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:
- Whether the trial court and the RTC erred in awarding civil liability against Caina despite his acquittal.
- 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:
- (Unlock)