Chantangco v. Abaroa

Background

A store owner sued to recover about $58,473.49 (Mexican) for a burned storehouse and its merchandise. The defendant, Eduardo Abaroa, had been tried criminally for the same burning and was acquitted. After the acquittal the owner brought a separate civil suit for compensation; the local trial court and the Supreme Court of the Philippine Islands ruled for Abaroa, and the case came here on a writ of error.

Reasoning

The key question was whether a criminal acquittal prevents a later civil claim for compensation for the same act. The Court applied the Philippine Civil and Penal Codes. Those laws treat civil liability that arises from crimes differently from ordinary negligence claims and say civil responsibility follows from criminal guilt. The criminal procedure statutes require that civil liability related to a crime be decided in the criminal sentence unless the injured person expressly reserves a separate civil action. Because the local codes make compensation part of the criminal consequence, an acquittal means the accused is exempt from that civil responsibility. The Court therefore affirmed the Philippine courts’ conclusion that a criminal acquittal barred the owner’s civil claim in this case.

Real world impact

People in the Philippines seeking compensation that springs from a crime must generally have that civil liability decided in the criminal proceeding. If a defendant is acquitted, local law can bar a later civil claim for the same criminal act. The Court relied on Philippine and Spanish authorities rather than common-law rules in reaching its decision.