People v. Moreno

Summary

This landmark 1934 Supreme Court case established that attachment of an accused's property is not available as a remedy in criminal proceedings under General Orders No. 58. Juan Moreno was convicted of homicide through reckless imprudence and ordered to pay P1,000 indemnity. When the victim's widow petitioned for attachment of his property fearing disposal to avoid payment, the Supreme Court denied the petition. The Court ruled that the Spanish-era attachment remedy was abrogated and cannot be replaced by civil procedure rules in criminal cases due to practical difficulties and procedural incompatibilities. The decision clarified that offended parties who choose to pursue civil remedies within criminal proceedings must accept only the protections offered by criminal procedure law, establishing important boundaries between criminal and civil procedural remedies in Philippine jurisprudence.