GR 35357; (January, 1932) (Digest)
G.R. No. 35357; February 2, 1932
GUILLERMO B. GUEVARA, plaintiff-appellee, vs. ROSAURO ALMARIO, MARCIANO ALMARIO, LA VANGUARDIA, INC., and MANUEL V. VILLAREAL, defendants. ROSAURO ALMARIO and MARCIANO ALMARIO, appellants.
FACTS
Defendant Rosauro Almario authored two clearly libelous articles published in La Vanguardia newspaper on March 3 and 16, 1927, attacking the official integrity and person of plaintiff Guillermo B. Guevara, the City Fiscal of Manila. In a prior criminal case, Almario pleaded guilty and was fined P400. Guevara then filed a civil action for damages totaling P100,000. At the civil trial, the plaintiff presented only the record, exhibits, and judgment from the criminal case as evidence. The defendants presented no evidence. The trial court rendered judgment against Rosauro Almario for P5,000 as general damages and P5,000 as punitive damages, absolving the other defendants.
ISSUE
1. Whether the trial court erred in admitting the record and evidence from the prior criminal case in the civil action.
2. What is the proper measure of damages to be awarded to the plaintiff?
RULING
1. The Supreme Court held that while a judgment of conviction in a criminal case is not generally admissible in a civil action, the fact of the defendant’s conviction and his express admission of authorship of the libel in the criminal case may be proved in the civil case. However, other portions of the criminal record, including the transcript of testimony, were inadmissible because no sufficient reason was shown for not producing the original witnesses in the civil case.
2. The Court modified the damages awarded. Special damages were not proven. Punitive damages were already imposed in the criminal action. For general (actual) damages, which arise by legal inference and need not be specifically proved, and considering the facts of the case, the Court, exercising its discretion, reduced the award. The majority concluded that an award of P1,000 was proper. The judgment was modified accordingly, condemning Rosauro Almario to pay the plaintiff P1,000 and the costs.
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