Petitioner
Danilo Waje
Respondent
Hon. Court of Appeals
Citation
G.R. No. 83206
Court
Supreme Court
Division
Second Division
Ponente
Sarmiento, J.
Decided
August 17, 1989

Summary

Danilo Waje was wrongfully charged with robbery based on misidentified fingerprint evidence and sworn statements by the Adriano spouses, who identified him as the perpetrator without proper verification. Waje was detained for over three months before the error was discovered and charges dismissed. He sued the Adrianos for damages, initially alleging malicious prosecution but later amending to negligence under Article 20 of the Civil Code. The trial court found the Adrianos liable for negligence, but the Court of Appeals reversed, applying malicious prosecution law instead. The Supreme Court affirmed the dismissal but clarified that the proper legal basis should have been negligence law, not malicious prosecution. However, the Court found no negligence as the Adrianos acted in good faith in reporting information to authorities, and it was the duty of law enforcement and prosecutors to verify the allegations properly.

Statutes applied

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By the Intellegal Editorial Board · August 17, 1989

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