G.R. No. 246674. June 30, 2020 (Case Brief / Digest)

**Title:** Jorge E. Auro (Represented by Heirs) vs. Johanna A. Yasis (Represented by Achilles A. Yasis)

Jorge E. Auro was charged with falsifying a public document, namely a notarized Deed of Absolute Sale, purporting to sell a fishpond owned by Johanna A. Yasis, who was in the US at the time. The case began in the Municipal Trial Court (MTC) of Mercedes, Camarines Norte, which convicted Auro but acquitted co-accused Fred Cornelio. Auro appealed to the Regional Trial Court (RTC), which acquitted him, holding the prosecution failed to prove the genuineness or falsity of Yasis’s signature and noting the notary had no commission. However, it ordered the cancellation of a tax declaration issued in Auro’s favor based on the deed. Auro, deceased during the appeal, was represented by his heirs at the Court of Appeals (CA), which affirmed the RTC’s decision but clarified that the cancellation of the tax declaration stemmed from the deed being invalid, not from Auro’s acquittal. The heirs then appealed to the Supreme Court.

1. Whether the cancellation of the tax declaration issued in Jorge E. Auro’s name as a result of the invalidated Deed of Sale was lawful.
2. Whether the civil aspect of Jorge E. Auro’s case for falsification of a public document was correctly adjudicated despite his criminal acquittal.

**Court’s Decision:**
The Supreme Court denied the petition, affirming the appellate court’s decision. The Court elaborated that the civil action for recovery of civil liabilities arising from the offense is considered implicitly instituted alongside the criminal case unless separately filed. It underscored that civil liability includes restitution, reparation of damage caused, and indemnification for consequential damages. The Court reasoned that the acquittal of Auro does not preclude the imposition of civil liability, which needs only to be proven by a preponderance of evidence. Since the Deed of Sale was invalidly notarized, it couldn’t affect the transfer of ownership reflected in the tax declaration, necessitating its cancellation.

Civil liability of an accused may exist independently of criminal liability and can be proven by preponderance of evidence. Restitution, as a form of civil liability, seeks to restore the status quo ante and is deemed instituted with the criminal action unless expressly filed separately.

**Class Notes:**
1. Civil Action with Criminal Cases: The civil aspect of a criminal offense is implicitly filed with the criminal case unless expressly stated otherwise.
2. Civil Liability in Acquittal: An individual’s acquittal in a criminal case does not automatically negate civil liability, which can be adjudicated based on a preponderance of evidence.
3. Principle of Restitution: Restitution aims to return or restore the aggrieved party to the original condition before the wrongful act occurred.
4. Preponderance of Evidence: This is the standard of proof used in civil cases, emphasizing that the evidence is more convincing than that presented by the opposing party.

**Historical Background:**
This decision reinforces the principle within Philippine jurisprudence that while criminal and civil liabilities are distinct, the determination of civil liability can proceed even if a criminal case results in acquittal. It highlights the balance the legal system seeks to maintain between the rights of the accused and the redress for the aggrieved party, emphasizing the aim of restoring harmed parties through civil remedies.


Leave a Reply

Your email address will not be published. Required fields are marked *

Apply Filters