Case Digest (G.R. No. L-39999) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Roy Padilla et al. vs. Court of Appeals (214 Phil. 492, May 31, 1984), petitioners Roy Padilla (municipal mayor), Filomeno Galdones, Ismael Gonzalgo and Jose Farley Bedena (policemen) were criminally charged with grave coercion for forcibly entering and demolishing Antonio Vergara’s market stall in Jose Panganiban, Camarines Norte on February 8, 1964. The Court of First Instance found the four guilty beyond reasonable doubt, sentencing them to five months and one day imprisonment, fines, and joint and several payment of P10,000 actual damages, P30,000 moral damages, and P10,000 exemplary damages. On appeal, the Court of Appeals acquitted petitioners for lack of proof of grave coercion but nonetheless ordered them to pay P9,600 as actual damages. Petitioners moved for reconsideration, arguing that their criminal acquittal extinguished any civil liability. The CA denied the motion, prompt Case Digest (G.R. No. L-39999) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Proceedings
- Petitioners
- Roy Padilla (incumbent municipal mayor of Jose Panganiban, Camarines Norte)
- Filomeno Galdones, Ismael Gonzalgo, Jose Farley Bedena (chief of police and policemen)
- Other co-accused (policemen and civilians) originally charged but some later acquitted by trial court.
- Respondent and relief sought
- Court of Appeals – modified trial court’s conviction, acquitted petitioners of grave coercion on reasonable doubt but imposed P9,600 actual damages.
- Petitioners filed petition for review on certiorari before the Supreme Court.
- Criminal Information and Trial Court Decision
- Information’s Allegations
- Grave coercion by means of threats, force and violence preventing Antonio Vergara and family from closing their market stall.
- Forcible entry, demolition of stall with axes, destruction of furniture, removal of goods; damage claimed P30,000; P20,000 exemplary damages.
- Accused took advantage of public positions; evident premeditation asserted.
- Trial Court Ruling (CII, Camarines Norte)
- Found petitioners Padilla, Galdones, Gonzalgo, Bedena guilty beyond reasonable doubt of grave coercion.
- Sentence: 5 months & 1 day imprisonment; P500 fine each; joint & several actual damages P10,000; moral P30,000; exemplary P10,000; accessory penalties and costs.
- Eight co-accused acquitted for reasonable doubt.
- Court of Appeals Modification
- Main Decision (Nov. 6, 1974)
- Acquitted petitioners of criminal liability for grave coercion on ground of reasonable doubt.
- Ordered petitioners to pay jointly & severally P9,600 as actual damages to the complainants.
- Resolution on Reconsideration (Dec. 26, 1974)
- Held civil liability not extinguished by acquittal based on reasonable doubt.
- Reasoned that demolition and property destruction were unlawful acts; proved damages.
- Petitioners’ Contentions Before the Supreme Court
- Acquittal of criminal liability extinguishes civil liability impliedly instituted with criminal action.
- Civil indemnity must be pursued in separate civil action, not in criminal case once acquitted.
- Cited precedents (People v. Pantig; Manila Railroad Co. v. Baltazar; Pueblo v. Abellera; People v. Manago; People v. Miranda; Aldaba v. Elepano).
Issues:
- Whether an acquittal based on reasonable doubt in a criminal case extinguishes the civil liability for damages impliedly instituted in the same action.
- Whether the Court of Appeals gravely erred or abused its discretion in awarding actual damages after acquitting petitioners of the crime charged.
- Whether the demolition of the market stall was a lawful execution of municipal ordinance or an unlawful act giving rise to civil liability.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)