Answer
Yes. Article 33 of the Civil Code allows a person who is defamed, defrauded, or physically injured to bring a civil action for damages that is entirely separate and distinct from the criminal prosecution, and that requires only a preponderance of evidence. The civil case may proceed independently and does not depend on the outcome of the criminal case.
The Supreme Court reads physical injuries in Article 33 in its generic sense — it covers bodily harm including consummated death, not only the specific crime of physical injuries in the Revised Penal Code (Carandang v. Santiago; Madeja v. Caro). Because the two cases are independent, an acquittal in the criminal case — which needs proof beyond reasonable doubt — does not bar the Article 33 civil action, which needs only a preponderance of evidence.
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