GR 234405; (December, 2020) (Digest)
G.R. No. 234405 , December 09, 2020
Martin N. Lim, Jr., Petitioner, vs. Maria Concepcion D. Lintag, Respondent.
FACTS
Maria Concepcion D. Lintag purchased a condominium unit from New San Jose Builders, Inc. (NSJBI). Petitioner Martin N. Lim, Jr., a sales agent of NSJBI, acted as the intermediary for her payments. On December 9, 2008, Lintag issued two crossed checks payable to NSJBI, which she entrusted to Lim for remittance. Lim claimed these checks were stolen from him during a robbery on his way home, an incident he failed to report immediately to Lintag or NSJBI. Subsequently, both checks were encashed, with one check showing clear alteration where the payee “New San Jose Builders, Inc.” was erased and replaced with “CASH.”
Lintag discovered the encashment and alteration in February 2009 and filed two separate criminal cases for estafa against Lim. The Regional Trial Court acquitted Lim of the criminal charges due to the prosecution’s failure to prove his guilt beyond reasonable doubt. However, the trial court found him civilly liable to Lintag and ordered him to pay damages. The Court of Appeals affirmed this finding of civil liability, prompting Lim to elevate the case to the Supreme Court.
ISSUE
Whether the petitioner, despite his acquittal in the criminal cases for estafa, can be held civilly liable to the private complainant.
RULING
Yes. The Supreme Court affirmed the petitioner’s civil liability. An acquittal in a criminal case does not automatically extinguish civil liability if such liability does not arise from or is not based on the criminal act of which the accused was acquitted. Here, the civil liability is predicated on the law on quasi-delicts or culpa aquiliana, which requires a separate finding of preponderance of evidence, a lower standard of proof than the reasonable doubt required in criminal cases.
The Court found that the petitioner, as an agent of NSJBI, had both material and juridical possession of the checks entrusted to him by Lintag. His failure to remit the checks or their value to NSJBI and his negligent act of not immediately reporting the alleged robbery, which facilitated the encashment of the altered check, established his culpable negligence. This negligence was the proximate cause of Lintag’s financial loss. Consequently, the Court upheld the award of actual damages amounting to P1,300,000.00, representing the total value of the checks, with legal interest. However, it deleted the awards for moral damages, exemplary damages, and attorney’s fees for lack of sufficient factual and legal basis.