Philippine National Bank vs Catipon

G.R. No. L-6662 – 98 Phil 286 – Civil Law – Torts and Damages – Effect of
Acquittal on the Civil Liability

Dalmacio Catipon bought onions from J.V. Ramirez and Co., Inc. in
1951. The son of Ramirez told Catipon that the only way he could get
the onions is for him to sign a trust receipt from Philippine National
Bank (PNB). Catipon at that time had no knowledge or intention to be
bound by the trust receipt but he signed it anyway so that he could
get the onions he already paid for. Catipon subsequently disposed of
the onions by selling them. Ramirez later became insolvent and the
trust receipt went unpaid and since it was in Catipon’s name, PNB
sued him for estafa for misappropriating the merchandise (onions).
The lower court acquitted Catipon because his guilt was not
satisfactorily established. Now PNB filed an action for recovery
against Catipon. Catipon assailed the civil suit and he argues that PNB
did not reserve its right to file a separate civil action.

ISSUE: Whether or not Catipon is still liable regardless of his acquittal

in the criminal case.

HELD: Yes. The acquittal was because of the fact that his guilt was not
satisfactorily established hence his acquittal was based on reasonable
doubt and under the law, such acquittal does not preclude a suit to
enforce the civil liability for the same act or omission, under Article 29
of the new Civil Code. This is even if there was no prior reservation by
PNB to file a civil suit. Catipon is ordered to pay PNB without
prejudice to Catipon’s rights against Ramirez.