Case Digest (G.R. No. L-30910)
Facts:
People of the Philippines v. Julia Maniego, G.R. No. L-30910, February 27, 1987, First Division, Narvasa, J., writing for the Court.An information filed in the Court of First Instance of Rizal charged three persons—Lt. Rizalino M. Ubay, Milagros T. Pamintuan, and Julia T. Maniego—with malversation of public funds totaling P66,434.50 for the period May–August 1957, alleging that Ubay, as disbursing officer, cashed worthless checks drawn by Pamintuan and indorsed by Maniego by using public funds in his custody. Only Ubay and Maniego were arraigned; Pamintuan had apparently left for the United States.
At trial both Ubay and Maniego pleaded not guilty. The Court of First Instance rendered judgment (dated June 10, 1964; promulgated August 6, 1964) convicting Ubay of malversation and sentencing him to reclusion temporal and a fine, while acquitting Maniego for lack of evidence on the criminal charge but ordering both Ubay and Maniego to pay jointly and severally P57,434.50 to the government. On reconsideration the trial court reduced the civil indemnity as to Maniego to P46,934.50 but otherwise denied relief.
Ubay appealed to the Court of Appeals; his appeal was later dismissed for failure to file a brief. Maniego timely appealed and assigned three errors concerning (1) whether her acquittal barred civil liability, (2) whether as an indorser she could be held liable for the dishonor of the checks, and (3) whether the trial court erred in adjudging joint and several liability with Ubay. Because the Court of Appeals viewed Maniego’s appeal as raising only questions of law, it certified the case to the Supreme Cou...(Pro-only)
Issues:
- Does an acquittal of the accused on the criminal charge (for lack of proof beyond reasonable doubt) bar imposition of civil liability for damages arising from the same acts?
- Can an indorser (or accommodation party) be held civilly liable for the dishonor of checks he or she indorsed that were used in the alleged malversation?
- Was it proper to adjudge Maniego jointly and severally liable with Ubay for reimbursement to the g...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)