Case Digest (G.R. No. 145823)
Facts:
Oscar Maccay and Adelaida Potenciano v. Spouses Prudencio Nobela and Serlina Nobela, G.R. No. 145823, March 31, 2005, First Division, Carpio, J., writing for the Court. Petitioners are Oscar Maccay (complainant in the criminal information) and Adelaida Potenciano (a prosecution witness); respondents are spouses Prudencio and Serlina Nobela (accused in Criminal Case No. 85961). The dispute arises from a transaction in which the Nobelas paid P300,000 for a parcel of land they believed was sold to them by the Maccays (through Potenciano’s representations).In May 1990 Potenciano — introducing herself to the Nobelas under the name Angelita N. Barba and presenting various land titles — and Maccay courted the Nobelas’ confidence, attended their home frequently and represented that properties could be sold for P300,000. On May 17, 1990 a Deed of Sale (Exh. 1) allegedly executed in favor of the Nobelas was notarized; they paid P300,000 and received documents including TCT No. 473584. Thereafter tax payments and registration steps were attempted; problems (a purportedly carnapped jeep, a hospital incident with alleged counterfeit currency, and suspicious dealings in registering the deed through a real estate agent, Anita de la Vega) gradually eroded the parties’ relationship.
On July 30, 1993 Potenciano executed an affidavit-complaint alleging she had been cheated and that the TCT had been stolen; the Provincial Prosecutor of Rizal filed an Information for Estafa through Falsification of Public Documents against the Nobelas in the Regional Trial Court (Pasig), Branch 70 (Criminal Case No. 85961). After trial the RTC, by decision dated January 26, 1995, acquitted the Nobelas and found that petitioners had swindled them; it ordered petitioners to reimburse P300,000 and to pay P50,000 moral damages and P40,000 attorney’s fees. Petitioners appealed the civil aspect to the Court of Appeals (CA-G.R. CV No. 49822); the Court of Appeals in a Decision dated September 25, 2000 (and ...(Pro-only)
Issues:
- May a trial court in a criminal case adjudicate and award civil damages against a complainant when the civil action was not reserved or separately filed?
- May a witness who is not a party to the criminal action be held liable for damages in the judgment of t...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)