G.R. No. 174654. August 17, 2011 (Case Brief / Digest)

### Title:
**Felixberto A. Abellana vs. People of the Philippines and Spouses Saapia B. Alonto and Diaga Alonto**

### Facts:
In 1985, Felixberto A. Abellana extended a loan to spouses Diaga and Saapia Alonto, which was secured by a Deed of Real Estate Mortgage over two lots in Cebu City. In 1987, Abellana prepared a Deed of Absolute Sale ostensibly transferring the lots to him. The Alontos signed this deed in Manila, but it was notarized in Cebu City without their personal appearance before the notary public. Subsequently, Abellana caused the transfer of the titles to his name and sold the lots to third parties.

On August 12, 1999, Abellana was charged with estafa through falsification of public document, alleging that he falsified the signatures of the Alontos to fraudulently transfer the property titles. He entered a plea of “not guilty,” and the case proceeded to trial.

### Procedural Posture:
1. **Regional Trial Court (RTC)**:
– **Decision (May 21, 2003)**: The RTC found Abellana guilty of falsification of public document by a private individual under Article 172(1) in relation to Article 171(2) of the Revised Penal Code, rather than estafa through falsification as charged. The court sentenced him to an indeterminate penalty and ordered reconveyance of the properties to the Alontos, with damages if reconveyance was not effected.

2. **Court of Appeals (CA)**:
– **Decision (February 22, 2006)**: The CA acquitted Abellana on the basis that he was charged with a different offense than he was found guilty of, violating his constitutional right to be informed of the charges. However, the CA affirmed the RTC’s imposition of civil liability on Abellana.
– **Resolution (August 15, 2006)**: CA denied Abellana’s motion for reconsideration.

3. **Supreme Court (SC)**:
– **Petition for Review on Certiorari**: Abellana contended that he should not be held civilly liable following his acquittal by the CA.

### Issues:
1. **Whether Felixberto A. Abellana could still be held civilly liable after his acquittal by the RTC and upheld by the CA**.

### Court’s Decision:
1. **Civil Liability Post-Acquittal**:
– The SC noted that while civil liability generally arises from the same act or omission attributed to an acquitted crime, it must be proven that the act directly caused damage.
– The RTC’s conviction for falsification was overturned because the charge was not based on a valid basis per the genuine signatures found.
– The SC ruled the spouses Alonto suffered no damage as they did sign the Deed, and its defective notarization did not nullify the transaction nor the resultant title transfer to Abellana.
– The SC further found the alternative sentence imposed by the RTC inappropriate as sentences must be definitive and certain as per jurisprudence.

The SC set aside the CA’s affirmation of civil liabilities, recognizing no factual or legal basis for the imposed reconveyance or damages.

### Doctrine:
1. **Principle of Acquittal Not Extinguishing Civil Liability**: The SC reiterated that acquittal from a criminal charge does not necessarily preclude civil liability unless the act from which the civil claim arose was proven not to have existed. This is consistent with established jurisprudence.

### Class Notes:
1. **Elements of Falsification (Article 172(1) and Article 171(2))**:
– Under Article 172(1): Any private individual who commits falsification in public documents or commercial documents.
– Under Article 171(2): Falsification occurs when an individual causes it to appear in any document that another person participated in an act/proceeding when said person did not.
2. **Jurisprudence on Civil Liability**:
– Acquittal may still result in civil liability if the court finds an act caused damage to another.
– Sentences must be definitive, not alternative, as expressed in United States v. Chong Ting and Ha Kang.

### Historical Background:
From a historical perspective, this case underscores the legal nuances in distinguishing between criminal and civil liabilities in the context of property transactions. It illustrates how procedural errors and factual clarifications in notarization can have significant implications on the outcomes of criminal charges, reinforcing the necessity for precise and proper adherence to legal formalities in property dealings. This case serves as a significant reference point in understanding the separation and interaction of criminal and civil liabilities within the Philippine judicial system.


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