Case Digest: Llonillo v. People, G.R. No. 246787, January 30, 2024

Criminal Law | What Civil Liability Includes

  • Spouses Llonillo entered into a “sangla-tira” arrangement with Pedro Joel Caspillo, who lent them ₱300,000 in exchange for temporary rights to collect rent from Unit H of their property.

  • They assured Caspillo that the unit was free of encumbrances, but it was later discovered that the unit was mortgaged and had been offered to other parties under similar arrangements.

  • Caspillo failed to collect rent and was not repaid the loan, prompting him to file a criminal complaint for estafa (Other Deceits under Article 318, RPC).

  • The trial courts convicted the spouses, but the Supreme Court later acquitted them, ruling that the elements of deceit were not sufficiently proven.

  • Whether civil liability may still be imposed on the accused despite their acquittal in the criminal case.

  • The Supreme Court ruled that although the spouses were acquitted of criminal liability, they are still civilly liable to Caspillo for the unpaid ₱300,000 loan.

  • Civil liability can survive acquittal if it arises from sources other than the criminal act—such as contracts, quasi-contracts, law, or quasi-delicts.

  • The loan agreement (MOA) between the parties is a valid contract, and the spouses admitted receiving the money.

  • Since they failed to repay the loan and offered no proof of payment, the Court found a preponderance of evidence supporting civil liability.

  • The Court awarded the full amount of ₱300,000 plus legal interest, even though the criminal charge was dismissed.

  • Article 29, Civil Code: Acquittal on reasonable doubt does not bar a civil action for damages.

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