Case Digest: Manantan vs. CA, G.R. No. 107125 January 29, 2001

                                Rule 120: Judgment, Acquittal | Criminal Procedure

Facts:

George Manantan was charged with reckless imprudence resulting in homicide for a car accident that caused the death of Ruben Nicolas.

The prosecution's evidence showed that Manantan, along with Ruben Nicolas and others, had been drinking beer throughout the day before the accident.

The defense claimed that the accident was caused by a passenger jeepney that swerved into their lane.
 
Manantan was initially acquitted by the trial court of homicide through reckless imprudence without a ruling on his civil liability.

On appeal from the civil aspect of the judgment, the Court of Appeals found Manantan civilly liable and ordered him to indemnify the parents of the deceased.


Issue:

WoN the court a quo err in finding that petitioner's acquittal did not extinguish his civil liability. (NO)

Contention:
Inasmuch as his civil liability is predicated on the criminal offense, he argues that when the latter is not proved, civil liability cannot be demanded. 
He concludes that his acquittal bars any civil action.

Held:

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 act or 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 delicto is 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 111 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.

Our scrutiny of the lower court's decision in Criminal Case No. 066 supports the conclusion of the appellate court that the acquittal was based on reasonable doubt; hence, petitioner's civil liability was not extinguished by his discharge. 

We note the trial court's declaration that did not discount the possibility that "the accused was really negligent." However, it found that "a hypothesis inconsistent with the negligence of the accused presented itself before the Court" and since said "hypothesis is consistent with the record…the Court's mind cannot rest on a verdict of conviction." 

The foregoing clearly shows that petitioner's acquittal was predicated on the conclusion that his guilt had not been established with moral certainty. Stated differently, it is an acquittal based on reasonable doubt and a suit to enforce civil liability for the same act or omission lies.

The assailed decision of the Court of Appeals, denying herein petitioner's motion for reconsideration, is AFFIRMED. Costs against petitioner

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