Jose Luis G. Yulo v. Arsenia Javier Celo

Summary

The Supreme Court ruled that criminal acquittal based on insufficiency of evidence does not extinguish civil liability when proven by preponderance of evidence. Jose Luis Yulo purchased three land parcels through broker Arsenia Javier Celo who represented herself as authorized agent of the owners. After paying P2,498,960.00 through installment checks, the properties were never transferred to Yulo's name, and one had an undisclosed mortgage. While Celo was acquitted of estafa due to variance between the criminal information and evidence presented, the Court found her civilly liable under the principle of solutio indebiti since she received payment without authority and failed to prove she delivered the proceeds to the actual vendors. The decision establishes that acquittal on insufficiency of evidence, unlike acquittal on reasonable doubt, allows civil liability to be determined separately under different standards of proof.