G.R. No. 216024 - Spouses Yu vs. Topacio, Jr.

Lidelia Maximo, the petitioner, initiated a petition for certiorari and mandamus aimed at compelling Judge Nicolas Gerochi, Jr. to include a civil liability award in his judgment of acquittal.
The underlying criminal case involved four informations for estafa filed by the City Fiscal of Bacolod against Conchita Panghilason.
The informations alleged that Panghilason issued four checks—amounting to a total of P35,586.00—which were dishonored due to reasons such as “lack of funds” or “account closed,” and that she failed to settle the payment within the prescribed period.

On July 10, 1976, the petitioner intervened in the criminal proceedings through her private prosecutor.
On December 5, 1977, the trial court rendered a judgment acquitting Panghilason in all four criminal informations on the ground that the prosecution failed to prove her guilt beyond a reasonable doubt.
In his judgment, the trial court observed that even if any obligation existed, it was essentially civil in nature and should be addressed separately in a civil action.

Following the acquittal, petitioner Maximo filed a motion for reconsideration. She requested that the judgment include the issue of civil liability, specifically ordering Panghilason to pay P33,586.00 plus 12% interest from July 10, 1976.
The trial court denied the motion, reasoning that the recovery of civil damages was not procedurally appropriate in a criminal proceeding where the accused was acquitted and that a separate civil suit would normally be required.

Detailed multiple transactions involving the purchase of rice from petitioner Maximo by the accused, with payment promised through postdated checks.
Exhibits presented included copies of checks, return slips indicating “account closed,” and signatures purportedly verifying the issuance of the checks.
Transactions spanned different dates (e.g., January 31, February 1, February 6, and February 7, 1976) and varied in amounts, cumulatively amounting to damages approximating P35,500.00.

The accused contended that she had an established credit arrangement with the petitioner dating back to 1973, which allowed for weekly purchases of rice on a 15-day credit basis.
She maintained that the postdated checks, although showing later dates in 1976, actually corresponded to transactions originally executed in 1975.
The defense acknowledged her indebtedness but shifted the focus to proving that the checks had been issued in fulfillment of a pre-existing civil contract rather than constituting criminal wrongdoing.

Despite the defense’s arguments, the accused did not fully oppose the claim of civil liability, effectively admitting the debt by her actions and the evidence presented.
The private respondent failed to file a satisfactory answer to the petition despite repeated notices from the Court.

The petitioner contended that, according to established precedents, a criminal judgment may include a civil liability award even if the accused is acquitted of the criminal charge.
Citing leading cases, such as Padilla v. Court of Appeals and People v. Jalandoni, the petitioner argued that there is no need for a separate civil action when the relevant facts have been adequately established during the criminal proceedings.
The petitioner maintained that requiring a separate action would lead to unnecessary duplication, increased judicial delay, and additional expense to the aggrieved party.

Whether the trial court erred in excluding the award of civil liability from the judgment of acquittal.

Does an acquittal on criminal charges preclude the simultaneous imposition of civil damages when the facts establishing a civil obligation have already been proven?

Whether the separate civil action requirement is mandatory even when the evidence of civil liability is indisputable.

Is it just and efficient to force the filing of a separate civil suit for damages when the criminal proceedings have already clarified the relevant facts?

The correct application of precedents concerning the incorporation of civil damages in a criminal judgment.

Should the principles enunciated in Padilla v. Court of Appeals and People v. Jalandoni be applied to permit the award of civil damages despite the acquittal on criminal charges?