This case has been cited 7 times or more.
|
2015-12-07 |
JARDELEZA, J. |
||||
| The rationale behind this rule is that in a criminal case, the party affected by the dismissal of the criminal action is the State and not the private complainant.[44] The interest of the private complainant or the private offended party is limited only to the civil liability.[45] In the prosecution of the offense, the complainant's role is limited to that of a witness for the prosecution such that when a criminal case is dismissed by the trial court or if there is an acquittal, an appeal therefrom on the criminal aspect may be undertaken only by the State through the Solicitor General.[46] The private offended party or complainant may not take such appeal, but may only do so as to the civil aspect of the case.[47] | |||||
|
2012-10-24 |
PERALTA, J. |
||||
| Worthy of note is the case of People v. Santiago,[25] wherein the Court had the occasion to bring this issue to rest. The Court elucidated: It is well-settled that in criminal cases where the offended party is the State, the interest of the private complainant or the private offended party is limited to the civil liability. Thus, in the prosecution of the offense, the complainant's role is limited to that of a witness for the prosecution. If a criminal case is dismissed by the trial court or if there is an acquittal, an appeal therefrom on the criminal aspect may be undertaken only by the State through the Solicitor General. Only the Solicitor General may represent the People of the Philippines on appeal. The private offended party or complainant may not take such appeal. However, the said offended party or complainant may appeal the civil aspect despite the acquittal of the accused. | |||||
|
2010-02-08 |
ABAD, J. |
||||
| But, when the trial court acquits the accused[19] or dismisses the case[20] on the ground of lack of evidence to prove the guilt of the accused beyond reasonable doubt, the civil action is not automatically extinguished since liability under such an action can be determined based on mere preponderance of evidence. The offended party may peel off from the terminated criminal action and appeal from the implied dismissal of his claim for civil liability.[21] | |||||
|
2009-12-23 |
NACHURA, J. |
||||
| This doctrine is laid down in our ruling in Heirs of Federico C. Delgado and Annalisa Pesico v. Luisito Q. Gonzalez and Antonio T. Buenaflor,[23] Cariño v. de Castro,[24] Mobilia Products, Inc. v. Umezawa,[25] Narciso v. Sta. Romana-Cruz,[26] Perez v. Hagonoy Rural Bank, Inc.,[27] and People v. Santiago,[28] where we held that only the OSG can bring or defend actions on behalf of the Republic or represent the People or the State in criminal proceedings pending in this Court and the CA. | |||||
|
2008-04-30 |
YNARES-SATIAGO, J. |
||||
| We are cognizant of our ruling in the cases of Perez v. Hagonoy,[15] Mobilia Products, Inc. v. Umezawa,[16] People v. Santiago,[17] and Narciso v. Sta. Romana-Cruz,[18] where we held that only the OSG can bring or defend actions on behalf of the Republic or represent the People or state in criminal proceedings pending in the Supreme Court and the Court of Appeals. At the same time, we acknowledged in those cases that a private offended party, in the interest of substantial justice, and where there appears to be a grave error committed by the judge, or where there is lack of due process, may allow and give due course to the petition filed. However, the special circumstances prevailing in the abovementioned cases are not present in the instant case. In those cases, the petitioners availed of petition for certiorari under Rule 65. In the instant case, the petition was filed under Rule 45. Moreover, both the Metropolitan Trial Court and the Regional Trial Court found that petitioner was not duly authorized by the owner of the subject property to collect and receive rentals thereon. Thus, not only were the checks without valuable consideration; they were also issued for a non-existing account. With these undisputed findings, we cannot reconcile petitioner's allegation that she is the aggrieved party. Finally, petitioner cannot validly claim that she was denied due process considering that she availed of every opportunity to present her case. Thus, we find no grave abuse of discretion on the part of the lower courts in dismissing the complaints. | |||||
|
2006-07-17 |
TINGA, J. |
||||
| The basic postulates concerning the capacity of a private complainant in the criminal case to seek judicial relief from adverse orders by the trial court were eloquently elucidated in People v. Santiago.[16] The elucidation deserves iteration as a proper closing. | |||||