Facts:

The case involves petitioners Diong Bi Chu, also known as Patrick Chang, Chang Ka Hee, and Lu Liong Corporation, against respondents Jaime Navoa and Milagros de Leos. The events leading to this case began when the private respondents filed a complaint before Military Commission No. 3, which was docketed as Criminal Case No. MC-3-57. The complaint charged the petitioners with estafa under Article 315, paragraph 2(a) of the Revised Penal Code. The allegations stated that the petitioners, through false pretenses and fraudulent acts, induced the private respondents to mortgage a parcel of land owned by Navoa, misappropriating the proceeds and causing damages amounting to P670,000.00. After the prosecution presented its evidence, Chang Ka Hee filed a demurrer to evidence, which led to the dismissal of the charges against him, as he was found to have no involvement in the transaction. On August 3, 1977, Military Commission No. 3 acquitted Diong Bi Chu, concluding that the transacti...

Facts:

1. Criminal Case Background:

   • Private respondents Jaime Navoa and Milagros de Leos filed a complaint before Military Commission No. 3, charging petitioners Diong Bi Chu (alias Patrick Chang) and Chang Ka Hee with estafa under Article 315, par. 2(a) of the Revised Penal Code.
   • The complaint alleged that the petitioners, through false pretenses and fraudulent acts, induced private respondents to mortgage a parcel of land registered in Navoa’s name and misappropriated the proceeds, causing damages amounting to P670,000.00.

2. Dismissal and Acquittal:

   • After the prosecution presented its evidence, Chang Ka Hee filed a demurrer to evidence, and the charge against him was dismissed as he had no involvement in the transaction.
   • On August 3, 1977, Military Commission No. 3 acquitted Diong Bi Chu, ruling that the transaction was a joint venture, and there was no fraud or deceit on his part. The loss was attributed to unforeseen risks, such as the prohibition of Virginia leaf tobacco importation.

3. Civil Action for Damages:

   • On March 31, 1978, private respondents filed a civil action for damages against Diong Bi Chu, Chang Ka Hee, and Lu Liong Corporation (where the petitioners were majority stockholders) before the Court of First Instance of Rizal, Branch 21, docketed as Civil Case No. 29077.
   • Petitioners moved to dismiss the civil action, arguing that it was barred by the prior judgment of Military Commission No. 3 and private respondents’ failure to reserve their right to file a separate civil action. The court denied the motion to dismiss, as well as subsequent motions for reconsideration.

4. Court of Appeals Ruling:

   • Petitioners filed a petition for certiorari before the Court of Appeals, which dismissed the petition. The appellate court held that the civil action for damages under Article 33 of the Civil Code is independent of the criminal case and that the acquittal in the criminal case did not bar the civil action.

Issue:

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Ruling:

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Ratio:

1. Independence of Civil Action:

   • Article 33 of the Civil Code allows a civil action for damages in cases of defamation, fraud, and physical injuries to proceed independently of the criminal case. The outcome of the criminal case, whether acquittal or conviction, is irrelevant to the civil action.

2. Preponderance of Evidence:

   • Civil liability under Article 33 requires only a preponderance of evidence, not proof beyond reasonable doubt as required in criminal cases.

3. No Reservation Required:

   • The requirement to reserve the right to file a separate civil action, as previously mandated by the Rules of Court, was deemed an unauthorized amendment to the Civil Code. The law itself provides for the independence of the civil action, making such a reservation unnecessary.

4. Prospective Application of Jurisprudence:

   • While the Supreme Court has ruled that military commissions lack jurisdiction over civilians, this principle applies prospectively and does not invalidate final judgments rendered before the ruling. Thus, the acquittal and dismissal by Military Commission No. 3 remain valid but do not bar the civil action for damages.