GR L 57555; (August, 1984) (Digest)
G.R. No. L-57555 August 28, 1984
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. TERESA JALANDONI, accused-appellant.
FACTS
Teresa Jalandoni was charged with estafa for issuing checks to the Bank of the Philippine Islands (BPI) that were dishonored for lack of funds, allegedly causing damage of P1,391,780.00. The trial court convicted her and ordered her to indemnify BPI. On appeal, the Supreme Court acquitted Jalandoni on the ground of reasonable doubt, rendering a judgment that contained no provision for civil liability.
Subsequently, BPI filed a Motion to Modify Judgment, seeking an order for Jalandoni to pay the civil liability despite her acquittal. BPI invoked a prior Court of Appeals decision and argued that the civil action was instituted with the criminal case. It prayed for payment of P1,391,780.00 with interest. Jalandoni opposed the motion, contending that the cited case was decided under old rules and that the amount of civil liability was unsettled and required proof.
ISSUE
Whether the Supreme Court, after acquitting the accused on reasonable doubt, can still adjudicate her civil liability to the private complainant.
RULING
Yes. The Supreme Court granted BPI’s motion and modified its earlier judgment to impose civil liability on Jalandoni. The Court, sitting En Banc, applied the doctrine established in Padilla vs. Court of Appeals, which held that a court can award damages in a criminal case despite a judgment of acquittal. The rationale is that when the civil action is instituted with the criminal action, and the facts necessary to establish civil liability have been thoroughly ventilated during the criminal proceedings, requiring a separate civil action would be a needless duplication causing undue clogging of court dockets and unnecessary expense.
The Court found Jalandoni’s opposition devoid of merit. In her own brief during the appeal, she had formally admitted the factual allegations in the information, including that BPI suffered damage in the amount of P1,391,780.00. Having made this judicial admission, she could not subsequently disclaim it or assert that the civil liability was unsettled. The Court held that such an about-face was an insult to its dignity and could not be permitted for mere convenience. Consequently, the Court ordered Jalandoni to pay BPI the admitted amount of P1,391,780.00 with legal interest from the filing of the action.