Petitioner filed a criminal action against the accused for uttering defamatory statement against him. The case was filled in the MTC which it found the accused guilty of the felony. However, the MTC did not grant any award for damages. Disagreeing with the decision, Petitioner appeal the civil aspect of the decision in the RTC. The RTC denied the appeal of the petitioner stating that as the criminal aspect attains finality in the MTC, the civil aspect also attains Finality. Dissatisfied, the Petitioner seeks the reverse the decision of the lower courts, hence this appeal.
Whether the Complainant who without reserving his right to file a separate civil action for damages is entitled to indemnification after the accused is found guilty.
Yes, Underlying the legal principle that a person who is criminally liable is also civilly liable is the view that from the standpoint of its effects, a crime has dual character: (1) as an offense against the state because of the disturbance of the social order; and (2) as an offense against the private person injured by the crime.
In the ultimate analysis, what gives rise to the civil liability is really the obligation of everyone to repair or to make whole the damage caused to another by reason of his act or omission, whether done intentional or negligently and whether or not punishable by law.
Also the SC categorically stated that from a judgment convicting the accused, two (2) appeals may, accordingly, be taken. The accused may seek a review of said judgment, as regards both civil and criminal actions; while the complainant may appeal with respect only to the civil action, either because the lower court has refused to award damages or because the award made is unsatisfactory to him. The right of either to appeal or not to appeal in the event of conviction of the accused is not dependent upon the other. Thus, private respondent’s theory that in actively intervening in the criminal action, petitioner waived his right to appeal from the decision that may be rendered therein, is incorrect and inaccurate. Petitioner may, as he did, appeal from the decision on the civil aspect which is deemed instituted with the criminal action and such appeal, timely taken, prevents the decision on the civil liability from attaining finality.