Case Digest (G.R. No. L-17389)
Facts:
The People of the Philippines v. Mamerto S. Miranda, G.R. No. L-17389, August 31, 1962, the Supreme Court En Banc, Paredes, J., writing for the Court.The People of the Philippines (plaintiff-appellee) prosecuted Mamerto S. Miranda (defendant-appellant) in the Court of First Instance of Quezon City for Estafa through Falsification of Commercial Documents under Article 315 in relation to Article 172 of the Revised Penal Code. After trial, the trial court acquitted Miranda of the criminal charge for lack of proof beyond reasonable doubt but, in the same judgment, found him civilly liable for P2,000.00 — the proceeds of a loan contracted by the offended spouses from the Rural Bank of Novaliches — on the court’s finding that Miranda had retained that amount pursuant to an arrangement with one of the spouses, Mariano Mojica. The trial court thus ordered Miranda to pay P2,000.00 with expenses, cancelled his provisional liberty bond, and imposed costs de oficio.
Miranda appealed only the portion of the judgment imposing civil liability. He argued that civil liability included in a criminal action must arise as a consequence of the criminal act; because he was acquitted, the civil liability could not stand. The Solicitor General agreed and recommended setting aside the payment order. The Court reviewed prior authorities, principally People v. Pantig, and related decisions, and resolved the appeal by setting aside the contested civil-judgment portion and permitting the off...(Subscriber-Only)
Issues:
- May a trial court, in the same criminal action, impose civil liability for an amount when the accused has been acquitted of the criminal charge?
- Did the trial court’s factual finding — that the accused retained P2,000.00 pursuant to an arrangement with one offended spouse — support imposing civil liability in ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)