Case Summary (G.R. No. L-39999)
Petitioners and Respondent
Petitioners: Roy Padilla, Filomeno Galdones, Ismael Gonzalgo, Jose Farley Bedena
Respondent: Court of Appeals
Key Dates
February 8, 1964 – Demolition of the Vergaras’ market stall
May 31, 1984 – Decision of the Supreme Court
Applicable Law
Revised Rules of Court (Rule 111 on civil liability in criminal actions); Revised Penal Code (Articles on grave coercion, malicious mischief); Civil Code Article 29; due process under the 1973 Constitution.
Facts of the Case
On February 8, 1964, petitioners, acting under municipal directives, forcibly entered the Vergaras’ market stall, inventoried and carted off goods, demolished the wooden structure with axes and heavy implements. The stall and merchandise suffered P9,600.00 in actual loss. The Vergaras paid rent and did not waive civil claims.
Trial Court Decision
The trial court convicted the four petitioners of grave coercion, sentenced them to five months and one day imprisonment, imposed fines, and awarded P10,000.00 actual damages, P30,000.00 moral damages, P10,000.00 exemplary damages, jointly and severally.
Court of Appeals Decision
The appellate court acquitted petitioners of criminal liability on reasonable doubt but ordered them to pay P9,600.00 actual damages jointly and severally, finding that acquittal did not extinguish civil liability because the wrongful demolition occurred and was undisputed.
Issues for Review
Whether the Court of Appeals gravely erred in imposing civil damages after acquitting petitioners of grave coercion; whether acquittal on reasonable doubt extinguishes civil liability impliedly instituted in a criminal action.
Supreme Court Ruling on Civil Liability
The Supreme Court affirmed the appellate ruling. It held that acquittal for lack of proof beyond reasonable doubt does not extinguish civil liability for physical damage unless a final judgment expressly declares the non-existence of the underlying facts. Rule 111, Section 3(c) governs that extinction of the penal action does not carry with it extinction of civil liability unless so declared.
Rationale on Civil and Criminal Liability
Civil liability arising from the same act is distinct from criminal liabil
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Procedural History
- Petition for review on certiorari filed before the Supreme Court from a decision of the Court of Appeals dated November 6, 1974, which modified a trial court judgment.
- Original criminal information for grave coercion filed in the Court of First Instance of Camarines Norte, Tenth Judicial District.
- Trial court convicted petitioners Roy Padilla, Filomeno Galdones, Ismael Gonzalgo and Jose Farley Bedena; imposed imprisonment, fines, and damages; acquitted several co-accused.
- Court of Appeals reversed and acquitted all appellants on ground of reasonable doubt as to grave coercion, but nevertheless ordered joint and several liability for actual damages in the amount of ₱9,600.00.
- Petitioners moved for reconsideration in the Court of Appeals, contending that their acquittal extinguished all civil liability; motion denied.
- Special civil action for certiorari brought before the Supreme Court contesting imposition of damages after acquittal.
Facts of the Case
- On February 8, 1964, at about 9:00 a.m., in Jose Panganiban, Camarines Norte, Mayor Roy Padilla issued a directive to clear certain market premises.
- Antonio Vergara and his family occupied a stall in Public Market Building No. 3, allegedly deemed a nuisance under municipal ordinance.
- Upon their failure to vacate within 72 hours, Chief of Police Galdones, Ismael Gonzalgo and Jose Farley Bedena, aided by policemen, forcibly opened and demolished the stall with axes, crowbars and hammers.
- The goods, wares and merchandise were inventoried, removed to the municipal building, and later remained unclaimed by the Vergaras.
- Vergaras claimed actual loss amounting to ₱9,600.00 (stall construction, furniture, equipment, goods).
Information and Charge
- Petitioners were jointly charged with the crime of grave coercion under Article 286 of the Revised Penal Code:
- Acts of threats, force and violence to prevent the Vergaras from closing and unloading their stall.
- Forcible entry, demolition of property, and carrying away merchandise.
- Alleged abuse of public positions—Mayor Padilla and town policemen.
- Alleged evident premeditation.
Trial Court Decision
- Found petitioners Roy Padilla, Filomeno Galdonez, Ismael Gonzalgo and Jose Farley Bedena guilty beyond reasonable doubt of grave coe