G.R. No. 76042 . February 23, 1990.
JOSE M. BELEN, petitioner, vs. HON. FELICIDARIO M. BATOY, RENATO SANCHEZ, PORFERIO, HAMAMA & BUSTILLO BAYOC, respondents.

FACTS

Petitioner Jose M. Belen, president of the Misamis Oriental-Bukidnon-Camiguin Federation of Cooperatives (MBC), was charged with estafa along with four co-accused. The information alleged they misappropriated the proceeds from the sale of tomatoes produced and delivered by farmer-members of the Mamdahilin Farmers Cooperative Association, Inc. (MFCAI). During trial, the public prosecutor moved to dismiss the case against Belen and two others for insufficiency of evidence, which the trial court granted. Trial proceeded against the remaining two accused.
The respondent judge rendered a decision acquitting the two remaining accused of criminal liability. However, the court held all five original accused, including petitioner Belen, jointly and severally civilly liable to the farmer-complainants. Belen filed motions for reconsideration, which were denied, prompting this certiorari petition challenging the imposition of civil liability upon him after the dismissal of the criminal case.

ISSUE

Whether an accused, whose criminal case has been dismissed due to insufficiency of evidence, can still be held civilly liable in the same proceedings.

RULING

Yes. The Supreme Court upheld the trial court’s decision imposing civil liability on petitioner Belen. The civil action was impliedly instituted with the criminal action. The dismissal of the criminal case against Belen did not extinguish his civil liability because the dismissal was based on insufficiency of evidence for the crime, not on a judicial declaration that the act from which civil liability might arise did not exist. The Court relied on Section 2, Rule 120 of the 1985 Rules of Criminal Procedure, which states that in case of acquittal, unless there is a clear showing that the act from which civil liability might arise did not exist, the judgment shall make a finding on the civil liability of the accused.
The civil liability here arose from contract or obligation, not exclusively from the felony charged. The trial court found that the transaction was a purchase and sale, creating a civil obligation to pay for the delivered tomatoes. This civil obligation could be adjudicated independently of the criminal proceedings. The Court cited precedents (Padilla v. CA, People v. Jalandoni) establishing that an accused may be acquitted on reasonable doubt for the crime but still be held civilly liable for damages proven during the trial.
The Court also rejected Belen’s claim of denial of due process. The trial court’s order dismissing his criminal case also set the date for the continuation of the trial, of which he was notified. His failure to appear constituted negligence. The facts necessary to establish the civil obligation had already been adduced during the criminal proceedings. Thus, the petition was dismissed for lack of merit.