Monday, July 3, 2023

Case Digest: Budlong vs. Judge Apalisok, G.R. No. 60151

Budlong vs. Judge Apalisok, G.R. No. 60151, June 24, 1983

Subject: Obligations and Contracts


FACTS
Camilo Puyo y Galagar was charged with slight physical injuries before the City Court of Tagbilaran City. He pleaded guilty to the charge and applied for probation. The City Court granted his application and placed him on probation for a period of two years.

The offended party, Salvador Budlong, filed a motion for hearing on the civil liability of Puyo. The City Court denied the motion, holding that the civil liability of Puyo was extinguished by the grant of probation.

Budlong filed a petition for certiorari with the Supreme Court, arguing that the City Court erred in denying his motion for hearing on the civil liability of Puyo.

ISSUE

Whether or not civil liability of the accused was extinguished.

RULING

No. The Supreme Court held that the City Court erred in denying the motion for hearing. The Court held that the grant of probation does not extinguish the civil liability of the accused. The Court reasoned that the Probation Law is silent on the matter of civil liability, and that the general rule is that the civil liability of a person convicted of a crime is not extinguished by his conviction. The Court held that the City Court should have set a hearing on the civil liability of Puyo. The Court remanded the case to the City Court for further proceedings.

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