GR L 37404; (November, 1991) (Digest)
G.R. No. L-37404 November 18, 1991
EDUARDO COJUANGCO, JR. and GRETCHEN OPPEN-COJUANGCO, petitioners, vs. THE HONORABLE COURT OF APPEALS, GEORGE F. SISON and LUIS R. MAURICIO, respondents.
FACTS
Petitioners-spouses filed a civil action for damages based on libel against the respondents, arising from a defamatory item published in the GRAPHIC magazine. This civil case was docketed as Civil Case No. Q-16725 and raffled to Branch XVI of the then Court of First Instance of Quezon City. Subsequently, a criminal case for libel was filed by the City Fiscal against the same respondents, docketed as Criminal Case No. Q-2713 and raffled to Branch V of the same court. Petitioners filed a motion to consolidate the criminal case with the earlier-filed civil case for joint trial, arguing it would promote judicial economy as the evidence would be substantially the same. Respondents opposed, contending no rule authorizes such consolidation, especially when cases are before different branches, and that it would create procedural conflicts.
ISSUE
May a criminal case for libel and an independent civil action for damages arising from the same libel, filed under Article 33 of the Civil Code, be consolidated for a joint trial?
RULING
Yes, consolidation is permissible. The Supreme Court granted the petition, reversing the Court of Appeals and reinstating the trial court’s consolidation order. The legal logic rests on the court’s inherent power to order consolidation to avoid multiplicity of suits, prevent unnecessary costs and delay, and serve the ends of justice. While the Rules of Court at the time lacked explicit provision for consolidating a criminal action with an independent civil action, such power is inherent in courts when the cases arise from the same facts and involve the same parties. The Court emphasized that practical considerations of economy and efficiency outweigh speculative fears of procedural chaos. The different standards of proof in civil and criminal cases do not preclude joint trial, as judges are competent to apply the respective standards to the evidence presented. Furthermore, the rule requiring libel cases to be filed in the same court supports the logic of unified proceedings. Consolidation is a matter of judicial discretion, duty-bound when cases are before the same court and one has not been partially tried, to ensure a speedy and inexpensive disposition.