Castillo Vs Salvador

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Castillo vs Salvador

Phillip Salvador was found guilty beyond reasonable doubt of the crime of estafa. CA reversed
the decision and acquitted the accused.

Petitioner files this petition on the civil aspect of the case alleging that despite the acquittal, the
award of damages should be retained.

Issue: Whether or not the there should be an award of damages despite the acquittal of the
accused.

Ruling:

The award of damages must be removed.

Our law recognizes two kinds of acquittal, with different effects on the civil liability of the
accused.
1. First is an acquittal on the ground that the accused is not the author of the actor omission
complained of. A person who has been found to be not the perpetrator of any act or omission
cannot and can never be held liable for such act oromission.
1. The second instance is an acquittal based on reasonable doubt on the guilt of the accused.
In this case, even if the guilt of the accused has not been satisfactorily established, he is not
exempt from civil liability which may be proved by preponderance of evidence only.

A reading of the CA decision would show that respondent was acquitted because the
prosecution failed to prove his guilt beyond reasonable doubt. The prosecution failed to prove
that all the elements of estafa are present in this case as would overcome the presumption of
innocence in favor of appellant. 

Thus, since the acquittal is based on reasonable doubt, respondent is not exempt from civil
liability which may be proved by preponderance of evidence only.

However, the civil liability was not proved even by preponderance of evidence. Hence it cannot
be awarded.

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