G.R. No. L-19104 December 26, 1963
THE PEOPLE OF THE PHILIPPINES and NG KOK CORPORATION, petitioner-appellant, vs. HILARIO DE CHAVEZ, GREGORIO PROTACIO, and JUAN MENDEZ, defendants-appellees.

FACTS

The accused-appellees were charged with theft of canvass valued at P2,800.00 belonging to the Ng Kok Corporation. Upon arraignment, all accused pleaded guilty to the amended complaint. The Municipal Court of Lucena City rendered a judgment sentencing each accused to imprisonment but made no pronouncement regarding their civil liability for restitution or indemnity.
The offended party, Ng Kok Corporation, filed a timely motion asking the court to amend the judgment to provide for civil liability. The municipal court denied this motion. It reasoned that a plea of guilty only admits the elements of the crime and does not extend to civil liability, which it deemed “evidentiary.” The court held it could not determine the nature and extent of civil liability based solely on the allegations in the complaint.

ISSUE

Whether the trial court erred in denying the motion to include civil liability in its judgment following the accused’s plea of guilty to the crime of theft.

RULING

Yes, the trial court erred. The Supreme Court set aside the order and remanded the case to the municipal court for further proceedings to determine civil liability.
The legal logic is clear. A plea of guilty constitutes an admission of all the material allegations in the complaint, including those pertaining to the civil liability arising from the crime, unless such liability is expressly waived or reserved. The institution of a criminal action inherently includes the civil action for recovery of civil liability, such as restitution or indemnity. The trial court’s omission to rule on this civil aspect was a lapsus or oversight.
The trial court’s justification—that civil liability is “evidentiary” and cannot be decided on mere allegations—is incorrect in the context of a guilty plea. Once guilt is admitted, the factual basis for civil liability is also established by that admission. However, recognizing the trial court’s apparent concern over specifically quantifying the value for restitution, the Supreme Court provided the proper remedy. Instead of outright denial, the trial court should have granted the motion and conducted a hearing to receive evidence on the exact value of the stolen property or the feasibility of its return. This procedure aligns with established precedent, where the Court has remanded cases to the trial court for the specific purpose of determining civil liability after a finding or admission of guilt.