People v. Celorico
REITERATIONFacts
The Antecedents: The defendant-appellee was convicted of slight physical injuries in the justice of the peace court of Dao, Antique. Subsequently, the Court of First Instance of Antique also found him guilty of the same offense. Procedural History: During the trial in the lower court, the prosecution sought to introduce evidence regarding the damages sustained by the complaining witness. However, the defense objected, and the court disallowed the evidence on the ground that the information lacked a specific allegation of such damages. The Petition: The People of the Philippines appealed the ruling of the lower court that disallowed the introduction of evidence on damages.
Issue(s)
Whether the lower court erred in disallowing evidence of damages sustained by the complaining witness due to the absence of a specific allegation in the information. Whether civil liability is determined in the criminal action.
Ruling
The order appealed from is reversed, and the case is remanded to the Court of First Instance of Antique with instructions to allow the prosecution to introduce evidence concerning the damages suffered by the injured party and to render judgment accordingly.
Ratio Decidendi
On the issue of disallowing evidence of damages: The Court held that 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 such liability or reserves the right to have civil damages determined in a separate action. In the present case, there was no waiver or reservation of civil liability. Therefore, evidence should have been allowed to establish the extent of the injuries suffered by the offended party and to recover the same, if proven. The ruling of the lower court disallowing such evidence was erroneous. On the determination of civil liability in criminal actions: The Court reiterated the principle that civil liability is an inherent consequence of criminal liability. The Revised Penal Code, in Article 100, explicitly states that every person criminally liable for a felony is also civilly liable. This principle is further supported by procedural rules that allow for the determination of civil damages within the criminal action itself. The purpose is to afford a complete and expeditious remedy to the injured party, consolidating all claims arising from the offense in a single proceeding. The exception to this rule, namely the waiver or reservation of civil liability, was not present in this case, thus reinforcing the applicability of the general rule.
Main Doctrine
In criminal actions, civil liability is determined therein unless expressly waived or reserved for separate action, and evidence of damages should be allowed even if not specifically alleged in the information.