Padilla v. Court of Appeals

Summary

Four municipal officials including Mayor Roy Padilla were charged with grave coercion for demolishing a market stall and taking merchandise. The trial court convicted them, but the Court of Appeals acquitted them on reasonable doubt, finding violence was against property not person as required for coercion. However, the CA imposed P9,600 civil damages. The Supreme Court affirmed, establishing the landmark principle that civil liability can be awarded in criminal proceedings even after acquittal on reasonable doubt, as long as the unlawful act causing damage is proven. The Court distinguished criminal liability (proof beyond reasonable doubt) from civil liability (preponderance of evidence), ruling that Article 29 of the Civil Code permits such awards without requiring separate civil action. This decision clarified the relationship between criminal and civil liability in Philippine jurisprudence.