Title
Biaban vs. Del Rosario
Case
A.M. No. 1349-CFI
Decision Date
Jan 5, 1978
A family dispute over property damage led to a malicious mischief case, ultimately dismissed due to lack of malice, with allegations of judicial bias unsuccessfully raised.
A

Case Summary (A.M. No. 1349-CFI)

Factual Background

The complaint arises from an initial case for Malicious Mischief that Coronacion P. Biaban filed against Bibiana P. Bautista, who is identified as her sister, along with other family members: Longinos Bautista (the husband) and their four sons, Ely, Godofredo, Eduardo, and Reynaldo. The case was originally brought before the Municipal Court of New Washington in Aklan, where the court dismissed the charges against Bibiana Bautista, citing her exemption from criminal liability due to her familial relationship with the complainant. Conversely, the other defendants were found guilty, receiving sentences of twenty days imprisonment and an order to indemnify the complainant in the amount of Fifty Pesos (₱50.00).

Appellate Proceedings

Upon appeal to the CFI presided over by Judge Del Rosario, all accused individuals were acquitted. The court's decision hinged on the finding that any damage, if it occurred, was not the result of malicious intent. Rather, evidence suggested that the damage to the complainant's property—specifically the cutting of a star apple tree and damage to vegetable plants—was inadvertently caused by Bibiana Bautista’s relocation of her son's house onto a portion of land that she owned.

Legal Principles Considered

The ruling underscored a fundamental element necessary for establishing the crime of malicious mischief: the presence of malice. The court concluded that there was no malice involved in the actions of Bibiana Bautista, thereby negating the existence of a criminal offense. Instead, any damages were deemed to evoke only civil liability for repair rather than criminal culpability.

Conclusion and

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