Odio, Diana Marie T. JD1
Manantan v. Court of Appeals
G.R. No. 107125, 29 January 2001
FACTS:
This is a petition for review of the decision dated January 31, 1992 of the Court of Appeals
modifying the judgment of the Regional Trial Court of Santiago, Isabela. Petitioner George
Manantan was charged with the crime of homicide through reckless imprudence. After trial,
petitioner was acquitted, but the trial court did not rule on his civil liability. On appeal, the appellate
court found petitioner civilly liable and ordered him to indemnify private respondents Marcelino
Nicolas and Maria Nicolas a total of P174,400.00 for the death of their son, Ruben Nicolas. Hence,
the present petition. Petitioner insisted that he was acquitted on a finding that he was neither
criminally negligent nor recklessly imprudent. Inasmuch as his civil liability is predicated on the
criminal offense, he argues that when the latter is not proved, civil liability cannot be demanded.
He concludes that his acquittal bars any civil action.
(Add a sentence describing what the crime of homicide is)
ISSUE:
Whether or not the acquittal extinguished the civil liability.
HELD:
The acquittal was based on reasonable doubt on the guilt of the accused. Article 29 of the Civil
Code provides that a civil liability is not extinguished in criminal cases. Therefore, the accused
cannot be exempted from paying civil damages which may only be proven by preponderance of
evidence.
Manantan claimed that he was placed in double jeopardy but the courts did not give merit to this
contention. The following elements must be present for double jeopardy to exist: (1) A first
jeopardy must have been attached prior to the second; (2) The first jeopardy must have
terminated; and (3) the third jeopardy must be for the same offense as the first.
RULING:
In the case at bar, he was initially put into jeopardy but he was terminated by his discharge. When
the case was elevated to the Court of Appeals, the issue was about the civil aspect of the criminal
case. Thus, there could be no double jeopardy.