Castillo v. Salvador, July 2014

 Castillo v. Salvador 
July 2014


Facts:
Respondents Phillip and Ramon Salvador were charged of the crime of estafa for allegedly defrauding petitioner in the amount of USD 100,000.00. The trial court held that the respondents are guilty beyond reasonable doubt. The Court of Appeals, however, acquitted them from the crime and in its decision, there was no dispositive portion that the petitioner may claim damages. The petitioner appealed in the SC for the civil aspect of the case.
Issue:
Whether or not  Petitioner may claim damages given that the respondents had been acquitted of the crime of estafa
Held:
​Yes. According to the Supreme Court, a reading of the CA decision would show that respondent was acquitted because the prosecution failed to prove his guilt beyond reasonable doubt.
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.