Case Digest (G.R. No. L-39999)
Facts:
Roy Padilla, Filomeno Galdones, Ismael Gonzalgo and Jose Farley Bedena v. Court of Appeals, G.R. No. L-39999, May 31, 1984, the Supreme Court En Banc, Gutierrez, Jr., J., writing for the Court.Petitioners (the four named men) were criminally charged by information with the crime of grave coercion for acts said to have occurred on February 8, 1964 in Jose Panganiban, Camarines Norte: by confederation and by threats, force and violence they allegedly prevented Antonio Vergara and his family from closing their market stall, forcibly opened and demolished the stall with axes and other instruments, and carried away goods and merchandise, producing alleged damages. The information further alleged abuse of public position (the mayor and policemen) and evident premeditation.
The Court of First Instance of Camarines Norte convicted petitioners Roy Padilla, Filomeno Galdonez (sic), Ismael Gonzalgo and Jose Parley (sic) Bedena of grave coercion, sentencing each to imprisonment of five months and one day, a P500 fine, and ordering joint and several payment of P10,000 actual/compensatory damages, P30,000 moral damages, P10,000 exemplary damages, and costs. Several co-accused were acquitted on reasonable doubt.
The petitioners appealed to the Court of Appeals, which reversed the convictions and acquitted the appellants on the ground of reasonable doubt; nevertheless, the Court of Appeals ordered the appellants to pay jointly and severally P9,600.00 as actual damages to the complainants. On reconsideration the Court of Appeals denied the petitioners’ motion, explaining that the acquittal was based on reasonable doubt (not on a finding that no unlawful act occurred) and that the civil liability for actual damages survived because the facts showing demolition and loss were established. The Court invoked Rule 111, Sec. 1 and Sec. 3(c) of the Rules of Court and Article 29 of the Civil Code in its analysis.
Petitioners thereafter filed this petition for re...(Subscriber-Only)
Issues:
- Did the Court of Appeals commit reversible error or grave abuse of discretion by ordering petitioners to pay civil damages after acquitting them of the criminal charge?
- Does an acquittal based on reasonable doubt extinguish civil liability arising from the same acts charged i...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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