Article 20 Case Digest: Caiña V. People

 MERLIN P. CAIÑA, PETITIONER, VS. PEOPLE OF THE PHILIPPINES

G.R. NO. 78777, SEPTEMBER 2, 1992

FACTS:

    The petitioner, Merlin P. Caiña, accused of reckless imprudence resulting in serious physical injuries, was acquitted of the criminal charge against him in a decision rendered by the Municipal Trial Court of Cagayan de Oro City, Branch 4. However, the petitioner was ordered to pay the private complainant, Dolores Perez, the sum of P2,893.40 representing actual damages.

    The Regional Trial Court reversed the decision of the trial court absolving the accused of civil liability. The private complainant subsequently filed a motion for reconsideration upon which the Regional Trial Court reversed its former decision, affirming the decision of the trial court making the petitioner liable for damages. 

ISSUES:

    Whether or not the MTC ruling for awarding damages is void and illegal.

RULING:

    Yes. With respect to the evidence presented by the prosecution, it is the thinking of the court that the most important or paramount factor in cases of this nature, is to evidently prove the recklessness, negligence and imprudence of the accused. The prosecution failed to show a clear and convincing evidence of such recklessness, negligence and imprudence. Prosecution witness Rene Abas stated that the speed of the jeep of the accused was on a regular speed or not so fast or just the very speed the jeep can run.

    It can be gleaned therefore from the decision that the act from which civil liability might arise does not exist.

    It is noted by the Court that in the dispositive portion of the decision of the Municipal Trial Court, the petitioner's acquittal was based on the ground that his guilt was not proved beyond reasonable doubt making it possible for Dolores Perez to prove and recover damages. However, from a reading of the decision of the Municipal Trial Court, there is a clear showing that the act from which civil liability might arise does not exist. Civil liability is then extinguished.

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