What are the 2 kinds of acquittal and their effect on the civil liability of the accused?

Our law recognizes two kinds of acquittal, with different effects on the civil liability of the accused. First is an acquittal on the ground that the accused is not the author of the act or omission complained of. This instance closes the door to civil liability, for a person who has been found to be not the perpetrator of any act or omission cannot and can never be held liable for such act or omission. There being no delict, civil liability ex delicto is out of the question, and the civil action, if any, which may be instituted must be based on grounds other than the delict complained of. This is the situation contemplated in Rule 111 of the Rules of Court. The second instance is an acquittal based on reasonable doubt on the guilt of the accused. In this case, even if the guilt of the accused has not been satisfactorily established, he is not exempt from civil liability which may be proved by preponderance of evidence only. (Lumantas vs. Calapiz, G.R. No. 163753, January 15, 2014 citing Manantan vs. CA, G.R. No. 107125, January 29, 2001)


2 kinds of acquittal:

1. Acquittal on the ground that the accused is not the author of the act or omission complained of
- accused is exempt from civil liability

2. Acquittal based on reasonable doubt on the guilt of the accused
- accused is not exempt from civil liability which may be proved by preponderance


When will an acquittal in a criminal action bar the civil action arising therefrom?

Acquittal in a criminal action bars the civil action arising therefrom where the judgment of acquittal holds that:

1. The accused did not commit the acts imputed to him;
2. He was not guilty of criminal or civil negligence. (Boado, Notes and Cases on the Revised Penal Code) 


When will an acquittal in a criminal action not bar the civil action arising therefrom?

 Acquittal in a criminal action will not bar the civil action arising therefrom where:

1. The acquittal is based on reasonable doubt as only a preponderance of evidence is required in civil cases;
2. The court declared that accused's liability is not criminal but only civil in nature;
3. The civil liability does not arise from or is not based upon the criminal act of which the accused was acquitted [refers to independent civil actions]. (Boado, Notes and Cases on the Revised Penal Code) 


 Does the acquittal of the accused in a criminal case a bar to the prosecution for damages based on quasi-delict?

No.  The acquittal of the accused, even if based on a finding that he is not guilty, does not carry with it the extinction of the civil liability based on quasi delict. A separate civil action lies against the offender in a criminal act, whether or not he is criminally prosecuted and found guilty or acquitted, provided that the offended party is not allowed, if he is actually charged also criminally, to recover damages on both scores, and would be entitled in such eventuality only to the bigger award of the two, assuming the awards made in the two cases vary. In other words, the extinction of civil liability referred to in Par. (c), Section 3, Rule 111 [now Rule 111, 2(b)], refers exclusively to civil liability founded on Article 100 of the Revised Penal Code, whereas the civil liability for the same act considered as a quasi-delict only and not as a crime is not extinguished even by a declaration in the criminal case that the criminal act charged has not happened or has not been committed by the accused. (Guaring, Jr. vs. Court of Appeals, G.R. No. 108395. March 7, 1997)