G.R. No. L-10070
December 1, 1915
PERFECTO ECLARIN, plaintiff-appellee, vs. THE MUNICIPALITY OF TAYABAS, defendant-appellant.

FACTS:
Perfecto Eclarin owned two parcels of coconut land in Barrio Baguio, Tayabas. On June 9, 1905, the Municipality of Tayabas, acting on a resolution passed in 1902 and without Eclarin’s consent or prior indemnity, entered his land, cleared a strip for a public road, and destroyed a number of his coconut trees (estimated between 30 to 177 trees). Eclarin protested and filed a damages suit in the justice of the peace court, which was later dismissed. The municipality ordered him to reopen the road, but he refused. In December 1911, the municipal president charged Eclarin criminally for violating the Road Law ( Act No. 1511 ). He was convicted by the justice of the peace but acquitted on appeal by the Court of First Instance, which found the municipality failed to prove the road was public. On January 24, 1912, Eclarin filed a civil action against the municipality, seeking ₱15,000 in damages: ₱8,000 for the land appropriation and destroyed trees (first cause of action), and ₱7,000 for moral and material damages from the criminal prosecution (second cause of action). The trial court awarded him ₱9,557.50. The municipality appealed, arguing prescription for the first cause and that the second cause did not constitute a valid action.

ISSUE:
1. Whether Eclarin’s right of action for damages from the 1905 taking of his land and destruction of trees had prescribed.
2. Whether Eclarin could recover damages for the criminal prosecution filed against him by the municipality.

RULING:

2. No, recovery for damages from the criminal prosecution is not allowed. The Court ruled that a civil action for damages arising from a false criminal accusation is barred under Article 326 of the Penal Code. This article requires that any prosecution for false accusation (whether criminal or civil) must be expressly ordered by the court that acquitted the accused or dismissed the case. Since the Court of First Instance, in acquitting Eclarin, did not order such a prosecution, no civil action for damages could proceed. The Court cited precedents (United States v. Barrera, Gonzalez Quiros v. Palanca Tan-Guinlay) holding that Article 326 applies to both criminal and civil actions against the complainant.

DISPOSITIVE PORTION:
The judgment of the trial court is REVERSED. The Municipality of Tayabas is ABSOLVED from the complaint. No costs.