G.R. No. L-45738; April 5, 1939
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. MAXIMIANO CELORICO, defendant-appellee.

FACTS

The defendant was convicted of slight physical injuries in the justice of the peace court. On appeal, the Court of First Instance also found him guilty. During trial, the prosecution attempted to introduce evidence on the damages sustained by the complaining witness, but the court disallowed it because the information did not specifically allege such damages. The prosecution appealed this ruling.

ISSUE

Whether the trial court erred in disallowing evidence of damages suffered by the offended party in the criminal action for slight physical injuries.

RULING

Yes. Under Article 100 of the Revised Penal Code, every person criminally liable for a felony is also civilly liable. This civil liability is determined in the criminal action unless the injured party expressly waives it or reserves the right to institute a separate civil action. Since there was no such waiver or reservation here, evidence to establish the extent of the injuries and the corresponding damages should have been allowed. The order was reversed, and the case was remanded to the trial court with instructions to allow the prosecution to introduce evidence on the damages.

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