G.R. No. L-7801 April 13, 1956
Testate Estate of Dña. Perpetua A. Vda. de Soriano. DOLORES ALBORNOZ, petitioner. ELIAS RACELA, claimant-appellant, vs. DOLORES ALBORNOZ and JOSE ALBORNOZ, co-special administrators oppositors-appellees.

FACTS

Elias Racela filed two claims against the estate of the deceased Perpetua Vda. de Soriano. The first claim was based on a deed of sale (Exhibit “A”) dated July 18, 1933, for one hectare of land at P1,000. The second claim was based on another deed of sale (Exhibit “B”) dated September 23, 1933, for another parcel at P1,000. After these purported sales, the decedent sold the same parcels to Soriano Ballesteros in 1934, who successfully registered the sale. When Racela attempted to register his deeds, the decedent opposed the registration. Racela subsequently filed a criminal action for estafa (Criminal Case No. 6406) against the decedent. The court acquitted the decedent, finding that Racela had not delivered any money as payment for the sale and that the deeds were executed only to enable Racela to convince residents of a barrio that the decedent could freely dispose of her properties, implying the sales were simulated. In the estate proceedings, after Racela presented his evidence, the trial court granted the administrators’ motion to dismiss the claims. The court reasoned that the acquittal in the criminal case, which was based on the same deeds of sale, exempted the decedent from civil liability.

ISSUE

Whether the judgment of acquittal in the criminal case for estafa bars the civil claims for payment based on the same deeds of sale.

RULING

Yes, the civil claims are barred. The Supreme Court affirmed the trial court’s dismissal. The Court examined the judgment of acquittal in the criminal case, which expressly declared that no actual sale took place and that Elias Racela did not deliver any money as payment. The court in the criminal case believed the deeds were simulated, executed only for the purpose of allowing Racela to show others that the decedent could dispose of her properties freely. This constitutes a judicial declaration that the facts from which the civil liability might arise (the sale and payment) did not exist. Consequently, under Section 1(d), Rule 107 of the Rules of Court (now relevant provisions under the Rules of Criminal Procedure), the extinction of the penal action carries with it the extinction of the civil action when the extinction proceeds from a final judgment declaring that the fact from which the civil might arise did not exist. Therefore, Racela’s civil claims are barred by the prior judgment of acquittal.