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CP-028 Corpuz v. Siapno
CP-028 Corpuz v. Siapno
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As to Judge Siapno failure to award Civil Damages in 2 Criminal Cases: o Hence, when no civil action is expressly instituted it shall be impliedly
o Records disclose both accused in cases pleaded Guilty to instituted with criminal action.
charges o It means that the civil action may be tried and prosecuted, with all the
o Criminal Case 1: P33.9k Repair on Damaged Property ancillary processes provided by law.
o Criminal Case 2: P34.7k and P15k Repair on Damaged Property
o Judge Siapno meted out a fine of P49.7k representing damages o Judge Siapno has been Administratively sanctioned 3 times before and
sustained by Offended Parties has obviously not reformed
o In justifying his omission to award civil damages, Judge Siapno alleges o More stringent penalties is warranted hence increase to P20k fine
prosecution did not present any evidence regarding Civil Aspect of case o Judge Siapno is found Guilty of Gross Ignorance of the Law and fined
P20k + stern warning
ISSUES
o W/N Judge Siapno is correct in not awarding Civil Damages – NO DISPOSITION
WHEREFORE, in view of all the foregoing, respondent Judge Orlando Ana F.
RULING & RATIO Siapno is found GUILTY of Gross Ignorance of the Law and is FINED the
o Judge Siapno should make a finding on the accused’s civil liability with amount of P20,000.00. He is also STERNLY WARNED that a repetition of
his rendition of Guilty verdict. It is basic that every person Criminally the same or similar offense in the future would be dealt with more severely.
Liable is also Civilly Liable.
o Article 2202 of Civil Code
o In crimes and quasi-delicts, the defendant shall be liable for all
damages which are the natural and probable consequences of
the act or omission complained of. It is not necessary that such
damages may have been foreseen or could have reasonably
been foreseen by the defendant.
o Sec 1 of RCP when complaint or information is filed without any
Allegation of Damages and Intention to prove and claim them, it is
understood that the Offended Party has Right to Prove and Claim for
them, Unless a Waiver or Reservation is made, or unless Offended Party
instituted Separate Civil Action.
o In such case the Civil Liability arising from Crime may be determined in
Criminal Proceedings. If Offended Party does not Waive to have it
Adjudged or does not Reserve Right to Institute a Separate Civil Action.
o If there is no Waiver or Reservation, then Evidence should be allowed to
Establish the extent of injuries suffered.
o Rules impose duty on courts to enter judgment with respect to Civil
Liability arising from offense. Even in case of acquittal, unless there is
clear showing that the act from which civil liability might arise did not
exist, judgment shall make a finding on Civil Liability of Accused in favor
of Offended Party.
o Hence – error for Judge Siapno not to have entered judgment with
respect to Civil Liability