CASTILLO vs. SALVADOR G.R. No. 191240, July 30, 2014

Respondent was accused of committing the crime of Estafa filed by the Petitioner. The RTC of Las Pinas found the respondent guilty of the said crime. Respondent appealed his conviction to the CA. The CA rendered its Decision reversing the decision of the RTC and acquitting the respondent. Petitioner files the instant petition onthe civil aspect of the case alleging that the trial court was correct in convicting the respondent so that even if the court of appeals decided to acquit him it should have at least retained the award of damages to the petitioner.

Whether the accused is still civilly liable after his acquittal in the criminal action

No, our law recognizes two kinds of acquittal, with different effects on the civil liability of the accused. First is an acquittal on the ground that the accused is not the author of the actor omission complained of. This instance closes the door to civil liability, for a person who has been found to be not the perpetrator of any act or omission cannot and can never be held liable for such act or omission. There being no delict, civil liability ex delictois out of the question, and the civil action, if any, which may be instituted must be based on grounds other than the delict complained of. This is the situation contemplated in Rule III of the Rules of Court. The second instance is an acquittal based on reasonable doubt on the guilt of the accused. In this case, even if the guilt of the accused has not been satisfactorily established, he is not exempt from civil liability which may be proved by preponderance of evidence only. This is the situation contemplated in Article 29 of the Civil Code, where the civil action for damages is “for the same act or omission.”


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