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ALFREDO PILI v. MARY ANN RESURRECCION.

FACTS:

Respondent Mary Ann Resurreccion entered into an agreement to purchase a house and lot from Conpil Realty Corporation. She issued two checks to Conpil for the payment but the checks were later dishonored due to "Account Closed" status. A criminal complaint was filed against respondent for violation of Batas Pambansa Blg. 22 or bouncing checks before the Municipal Trial Court (MTC). The criminal case was captioned as "People of the Philippines v. Mary Ann Resurreccion" and was signed by petitioner Alfredo Pili, Jr., who was the President of Conpil Realty Corporation at the time. After trial, the MTC acquitted respondent but ordered her to pay P500,000 as civil indemnity. Both parties appealed the MTC's ruling to the Regional Trial Court (RTC), but the RTC affirmed the MTC's judgment. Respondent filed a petition for review with the Court of Appeals (CA) to challenge the civil liability imposed on her. The CA granted respondent's appeal, finding that the criminal case was not prosecuted in the name of the real party in interest, which was Conpil Realty Corporation. The CA set aside the RTC's decision and order, without prejudice to the real party in interest filing a separate action against respondent. Petitioner now questions the CA's ruling.

ISSUES:

  1. Whether Palmer Asia, Inc is the real party-in-interest in the civil aspect of the case.

  2. Whether the inclusion of Palmer Asia, Inc in the case is proper.

  3. Whether or not the Court of Appeals (CA) committed an error in ruling that the complainant should have been included in the title of the case.

RULING:

  1. No, Palmer Asia, Inc is not the real party-in-interest in the civil aspect of the case. The real party-in-interest is Andrews International Products, Inc, as they are the payee of the bounced checks and the complainant in the criminal case.

  2. No, the inclusion of Palmer Asia, Inc in the case is not proper. They are a separate and distinct entity from Andrews International Products, Inc, and therefore cannot claim civil liability against the accused.

  3. The Court ruled that the CA committed a gross error in ruling that the complainant should have been included in the title of the case. The Court found that the criminal complaint was indeed filed and prosecuted in the name of the real party in interest, which was the complainant corporation. It was the respondent who changed the title of the case when she filed her petition for review with the CA. The CA's failure to consider the facts and documents presented before it, as well as its unjust punishment of the complainant by dismissing the appeal and setting aside the civil liability awarded, constituted gross manifest error and grave abuse of discretion. The Court also reiterated that the inclusion of the names of all parties in the title of a complaint is a formal requirement but the non-inclusion of one or some of them is not fatal as long as there is a statement in the body of the petition indicating that they were made parties to the action.

PRINCIPLES:

  • In criminal cases, the People is the real party-in-interest, and the private offended party is limited to the aspect of civil liability.

  • The action in the name of the real party-in-interest must be prosecuted, and parties who are not the real parties-in-interest may be included in a suit under certain circumstances.

  • A real party-in-interest is the party who stands to be benefited or injured by the judgment in the suit.

  • The private complainant is the real party-in-interest only as regards the civil aspect arising from the crime.

  • Pleadings shall be construed liberally so as to render substantial justice to the parties and determine the actual merits of the controversy with the least regard to technicalities.

  • The non-inclusion of a party in the title of a complaint is not fatal if there is a statement in the body of the petition indicating that the party was made a defendant in the action.