G.R. No. A.M. No. 1541-MJ November 21, 1980
FIDEL MORTA, SR., complainant, vs. MUNICIPAL JUDGE CIPRIANO B. ALVIZO, JR. of Santiago, now Cabadbaran, Agusan del Norte, respondent.

FACTS

On November 10, 1976, in Criminal Case No. 090 before the Municipal Court of Santiago, Agusan del Norte, respondent Judge Cipriano B. Alvizo, Jr. rendered a decision in open court immediately after the accused, Edilberto Magayones, pleaded guilty to the charge of less serious physical injuries. The judge convicted Magayones, applying his plea as a mitigating circumstance, and sentenced him to two months of arresto mayor. The decision did not impose any civil liability for damages. Complainant Fidel Morta, Sr., the father of the victim, was dissatisfied as his son had incurred medical expenses from hospitalization due to the injuries. The judge explained to Morta that the victim’s presence at arraignment was unnecessary and that reimbursement for medical expenses was not possible because the prosecution presented no evidence on damages after the guilty plea.
Morta filed an administrative complaint, alleging the judge “prostituted the judicial process” by rendering judgment without a trial and failing to address the civil liability for the victim’s medical costs. He argued that the judge overlooked the fundamental rule that criminal liability includes civil liability, and that a hearing should have been conducted to receive evidence on damages despite the guilty plea.

ISSUE

Whether respondent Judge Alvizo, Jr. committed an error in failing to set a hearing for the reception of evidence on civil liability after the accused’s plea of guilty, thereby warranting administrative sanction.

RULING

Yes, the Supreme Court found respondent judge administratively liable for negligence. The legal logic is anchored on the doctrine of implied institution of the civil action with the criminal action. Under Article 100 of the Revised Penal Code and Section 1, Rule 111 of the Rules of Court, every person criminally liable for a felony is also civilly liable. When a criminal action is instituted, the civil action for recovery of civil liability arising from the offense is deemed impliedly instituted alongside it, unless the offended party expressly waives the civil action or reserves the right to institute it separately.
The Court emphasized that a plea of guilty only admits the commission of the crime and its essential elements, not the actual civil liability. Therefore, after Magayones pleaded guilty, Judge Alvizo should have set the case for a hearing specifically for the reception of the offended party’s evidence regarding the civil liability, such as medical expenses. This procedural requirement ensures that the civil aspect is duly adjudicated, as established in Veloso vs. Carmona (Adm. Matter No. 502-MJ, June 30, 1977). The civil liability may be claimed even without specific allegations of damages in the criminal complaint, as the court can determine it based on evidence presented during a hearing.
Consequently, the Supreme Court warned and admonished Judge Alvizo to be more careful in performing his judicial duties to avoid such oversights in the future. A copy of the resolution was ordered attached to his personal record.