G.R. No.

107125 January 29, 2001

MANANTAN vs COURT OF APPEALS
FACTS:
On June 1, 1983, the Provincial Fiscal of Isabela filed an Information charging
petitioner Manantan with reckless imprudence resulting to homicide committed on or
about the 25th of September 1982, in Santiago, Isabela. The said accused being the
driver of an automobile bearing Plate No. NGA-816 unlawfully drove the vehicle, in a
negligent manner causing the car to sideswipe a passenger jeepney, thereby casuing
the death of Ruben Nicolas. In its decision date June 30, 1982, promulgated on August
4, 1988, the trial court decided the criminal case in favor of the Manantan. Subsquently,
the private respondent spouses Nicolas filed their notice of appeal on the civil aspect of
the trial courts judgment. On it decision, CA decided in favor if the private respondents.
In finding the petitioners civil liability, the court a quo noted that at the time of the
accident, Manantan was in a state of intoxication, due to his having consume all in all a
total amount of at least twelve bottles of beer between 9 am to 11pm.
ISSUE:
Whether or not the acquittal of the accused also extinguished the civil liability.
HELD:
No, in the case at bar, the accuseds acquittal is based on reasonable doubt. Since civil
liability is not extinguished in criminal cases if the accused acquittal is based on
reasonable doubt. The decision of the Court of Appeals finding that the defendant is
civilly liable for his negligence and reckless act of driving his car which was the
proximate cause of the accident and sentenced him to indemnify plaintiff-appellants in
the amount of P74,400.00 for the death of Ruben Nicolas. Although the two actions
have different purposes, the matters discussed in the civil cases are similar to those in
the criminal case. The parties are different and different rules of evidence are
applicable.

302 U.S. 319

PALKO vs CONNECTICUT
FACTS:
Defendant was indicted for murder in the first degree. The jury returned a conviction of murder
in the second degree, for which he received a life sentence. The State of Connecticut appealed
and the Connecticut Supreme Court of Errors reversed the judgment and ordered a new trial.
This court found harmful error to the state as a result of the exclusion of testimony as to a
confession by the defendant, the exclusion of cross-examination testimony to impeach the
defendant, and faulty jury instructions as to the difference between first and second degree
murder. They ordered a second trial at which the jury sentenced the defendant to death. The
defendant was granted certiorari to have the second conviction overturned.
ISSUE:
Whether or not the double jeopardy prohibition was violated.
HELD:
No. The Supreme Court of the United States affirms the first degree murder conviction and the
accompanying
death
sentence.
Two requirements need to be met for a state to appropriately choose to not include the
prohibition on double jeopardy. They do not have to incorporate such a right if it is not of the
very essence of a scheme of ordered liberty, and if its abolishment would not violate a principal
of justice so rooted in the traditions and conscience of the American people as to be ranked
fundamental. The Supreme Court saw the states allowing a second trial on the same facts as
not violating fundamental principles of liberty and justice because it was only done to make sure
that there was a trial without legal error.