1 Padilla v Court of Appeals (1984) [Concept: Culpa Aquiliana, Quasi-delict, Torts]

Ipan, Jhon Edgar

Padilla v. Court of Appeals

G.R. No. L-39999
May 31, 1984

Facts: An information was filed charging Padilla and several other accused with the crime of grave
coercion for unlawfully and feloniously, by means of threats, force, and violence, preventing Vergara and
his family to close their stall located at the Public Market, Building No. 3, Jose Panganiban, Camarines
Norte, and by subsequently forcibly opening the door of the said stall and thereafter brutally demolishing
and destroying said stall and the furnitures therein by axes and other massive instruments, and carrying
away the goods, wares, and merchandise, to the damage and prejudice of the said Antonio Vergara and
his family. CFI of Camarines Norte found Padilla, Galdonez, Gonzalgo, and Bedenia guilty of grave
coercion. The petitioners appealed the judgment of conviction to the Court of Appeals. CA modified the
judgment appealed from, stating that the appellants are acquitted on the ground of reasonable doubt but
they are ordered to pay jointly and severally to complainants the amount of P9,600.00, as actual
damages. The petitioners filed a motion for reconsideration contending that the acquittal of the
defendants-appellants as to criminal liability results in the extinction of their civil liability. The Court of
Appeals denied the motion. As a result, the petitioners filed a petition for review on certiorari in the
Supreme Court.

Issue: Whether or not the Court of Appeals committed a reversible error in requiring the petitioners to pay
civil indemnity to the complainants after acquitting them from the criminal charge.

Held: No. The Court affirmed the decision of the CA and dismissed the petition for lack of merit.
According to the court, the judgment of acquittal extinguishes the liability of the accused for damages only
when it includes a declaration that the facts from which the civil might arise did not exist. Thus, the civil
liability is not extinguished by acquittal where the acquittal is based on reasonable doubt as only
preponderance of evidence is required in civil cases. The Civil Code provision does not state that the
remedy can be availed of only in a separate civil action. A separate civil case may be filed but there is no
statement that such separate filing is the only and exclusive permissible mode of recovering damages.
There is nothing contrary to the Civil Code provision in the rendition of a judgment of acquittal and a
judgment awarding damages in the same criminal action. The two can stand side by side. A judgment of
acquittal operates to extinguish the criminal liability. It does not, however, extinguish the civil liability
unless there is a clear showing that the act from which civil liability might arise did not exist. Also, the
Court ruled that considering the delays suffered by the case in the trial, appellate, and review stages, it
would be unjust to the complainants to require a separate civil action to be filed.