THE PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. TERESA JALANDONI, ACCUSED-APPELLANT.

People versus Jalandoni

The Case

This is the People of the Philippines against Teresa Jalandoni, a criminal case for estafa arising from several dishonored checks. The accused was convicted by the trial court, then acquitted by the Supreme Court on reasonable doubt. What makes the case matter is what happened after the acquittal: the offended bank asked the Court to modify its own judgment so as to hold the accused civilly liable anyway. The case therefore stands at the intersection of criminal acquittal and civil liability, and it is the companion of the Court's ruling in Padilla versus Court of Appeals on whether damages may be awarded despite an acquittal.

Procedural History

Teresa Jalandoni was charged with estafa before the Circuit Criminal Court of Manila. The trial court found her guilty beyond reasonable doubt and sentenced her to reclusion perpetua, ordered her to indemnify the Bank of the Philippine Islands, Cervantes Branch, in the sum of 1,600,000 pesos representing the balance of the amount she swindled from the bank, and to pay the costs.

She appealed to the Supreme Court. The Court set aside the judgment of conviction and entered a new one acquitting her, because her guilt was not demonstrated beyond reasonable doubt.

The Bank of the Philippine Islands then filed a Motion to Modify Judgment as to the appellant's civil liability, invoking a Court of Appeals decision where an accused acquitted of malversation on reasonable doubt was nonetheless ordered to pay her civil liability. The motion was first before the Second Division, which had rendered the acquittal. Because the motion called for the application of a novel doctrine, the case was referred to the Court En Banc. The Court En Banc thereafter promulgated its decision in Padilla versus Court of Appeals, holding that the Court of Appeals did not err in awarding damages despite a judgment of acquittal. The Court then resolved the bank's motion in this case.

Facts

The information alleged that Teresa Jalandoni issued several checks drawn against the Rizal Commercial Banking Corporation in favor of the Bank of the Philippine Islands; that the checks were dishonored for lack of funds, a fact known to the accused; and that as a result the bank suffered damage in the amount of 1,391,780 pesos.

In her brief on appeal, Jalandoni admitted the following: that she issued nine personal checks of the Rizal Commercial Banking Corporation; that the total face value of the nine checks was 2,150,000 pesos; that one check, in the amount of 200,000 pesos, was honored when the checks went through clearing; that the checks she drew against those personal checks aggregated 2,041,780 pesos; that those checks were drawn in favor of third parties, not herself; and that out of the 2,150,000 pesos worth of the nine checks, the damage suffered was only 1,391,780 pesos.

After her acquittal, the bank moved to modify the judgment to include an award of civil liability. In its subsequent pleading the bank reduced its claim to 1,391,780 pesos, the very figure the accused had admitted, and asked for interest at the legal rate of twelve percent per annum from the filing of the action until payment. The accused opposed the motion, arguing that the Court of Appeals case invoked was not in point because it was decided under the old Rules of Court, and that the amount of civil liability, if any, was unsettled and required the introduction of proof.

Issues

• Whether or not the civil liability of an accused may be adjudged in the same criminal case despite her acquittal on reasonable doubt.
• Whether or not the amount of the civil liability is unsettled and requires the introduction of proof.

Applicable Provisions

The decision refers to the crime of estafa as defined under Article 315, paragraph 2, subparagraph a, of the Revised Penal Code, which the trial court applied in convicting the accused. It bears on the case because the criminal charge, though ending in acquittal, arose from the same dishonored checks that ground the civil claim.

Article 315, 2(a).

The Court also relied on its ruling in Padilla versus Court of Appeals, which it quoted as the governing doctrine on damages after acquittal:

There appear to be no sound reasons to require a separate civil action to still be filed considering that the facts to be proved in the civil case have already been established in the criminal proceedings where the accused was acquitted. Due process has been accorded the accused. He was, in fact, exonerated of the criminal charge. The constitutional presumption of innocence called for more vigilant efforts on the part of prosecuting attorneys and defense counsel, a keener awareness by all witnesses of the serious implications of perjury, and a more studied consideration by the judge of the entire records and of applicable statutes and precedents. To require a separate civil action simply because the accused was acquitted would mean needless clogging of court dockets and unnecessary duplication of litigation with all its attendant loss of time, effort, and money on the part of all concerned.

Ruling

On the first issue, the Court granted the motion. It held that the civil action was instituted at the commencement of the criminal action, and that the facts needed to establish the civil liability had already been established in the criminal proceedings. Following Padilla versus Court of Appeals, there was no sound reason to require a separate civil action simply because the accused had been acquitted. To do so would needlessly clog court dockets and duplicate litigation.

On the second issue, the Court rejected the accused's claim that the amount was unsettled. It pointed to her own admissions in her brief, where she formally admitted that the bank suffered damage in the amount of 1,391,780 pesos. The Court said her assertion that the civil liability was unsettled was utterly devoid of merit, and it declared:

We cannot allow a party to state a fact only to disown it afterwards because of convenience.

Doctrine

A judgment of acquittal on reasonable doubt does not bar the award of civil liability in the same criminal case where the civil action was instituted at the commencement of the criminal action and the facts needed to prove that liability were already established in the criminal proceedings. The accused has been accorded due process; requiring a separate civil action would only clog court dockets and duplicate litigation. A party is bound by the admissions made in her own pleadings and briefs, and may not disown a formally admitted fact merely because it has become inconvenient.

Disposition

The motion was granted, and the Court modified its judgment so that the appellant was ordered to pay the Bank of the Philippine Islands 1,391,780 pesos with interest at the legal rate of twelve percent per annum from the filing of the action until paid.

Remember This

Memorize the line: an acquittal on reasonable doubt does not extinguish civil liability where the facts were already established in the criminal case. Examiners use this case to test the civil liability of an acquitted accused, and the binding effect of a party's own admissions.