Corpus v.
Siapno
G.R. No. A.M. No. MTJ-96-1106 | June 17, 2003 | Ynares-Santiago, J.
Petitioner: Celestina Corpuz, Clerk of Court, MTC Urdaneta, Pangasinan
Respondent: Judge Orlando Ana F. Siapno, Presiding Judge, MTC
Urdaneta, Pangasinan
Rule 111 Rules of Criminal Procedure, Section 1
DOCTRINE
When no civil action is expressly instituted it shall be impliedly instituted with
criminal action.
Relevant Provision
Rule 111. Section 1. Institution of Criminal and Civil Action.
xxx
Where the civil action has been filed separately and trial thereof has not yet
commenced, it may be consolidated with the criminal action upon application
with the court trying the latter case. If the application is granted, the trial of
both actions shall proceed in accordance with section 2 of this Rule
governing consolidation of the civil and criminal actions.
FACTS
o Clerk of Court of MTC Urdaneta, Pangasinan Celestina Corpuz filed an
Affidavit Complaint against Presiding Judge Orlando Ana Siapno
charging him with Violation of Admin Circular 3-92 and 17-94, Anti-Graft
and Corrupt Practices Act, Falsification, Conduct Unbecoming of a Public
Officer, Abuse of Authority, Delay in Administration of Justice and
Ignorance of the Law
o Corpuz alleged that Siapno:
o Proposed to her they extort money from litigants immediately
upon assumption of office
o Used his chambers as residence
o Failed to make the required inventory of cases
o Allowed his family to use a typewriter issued by the SC
o Dismissed 5 Criminal Cases against his friend and drinking
companion Captain Javonillo
o Falsified Certificate of Service by stating he conducted sessions
everyday when absent on Thursdays and Fridays
o Intimidated 3 police officers who filed complaints for Grave
Slander against him
o Maligned complainant in presence of public
o Sent his court personnel on personal errands such as marketing
chores and washing dishes
o Dismissed rape case despite interest of DSWD in case since
victim was minor
o Returned Criminal Cases for barangay conciliation despite
presence of certificates to file action but entertained
countercharges despite lack of said certifications
o Failed to resolve 3 Criminal Cases within period prescribed by
SC
o Failed to award Civil Damages in 2 Criminal Cases
o Instigated persons to stage a demonstration against Corpuz
o Ordered Corpuz to drop case for Robbery since filed by Corpuz
niece
o Apr 7 1997 – Siapno vehemently denied the charges and averred:
o Sleeps in his house in Dagupan and Asingan
o Inventory of cases was done by Judith Tambo under his
supervision
o Filing cabinet in his court not being used for kitchen utensils and
personal belongings
o He owns 3 typewriters and 1 personal computer in his house
o Not have drinking sessions with Captain Javanillo
o Holds sessions only from Mondays to Wednesdays because
Public Prosecutor and PAO layers assigned to his branch are
available on those days
o 3 Policemen voluntarily withdrew cases for grave slander against
him
o Resolution dismissing 3 rape cases were affirmed by Provincial
Prosecutor
o Referred 3 criminal cases to Barangay for conciliation because
validity of certifications to file action was questioned by counsel
o All cases forwarded to his chambers are decided and resolved
with dispatch
o Not award civil damages in 2 Criminal Cases because
prosecution not present any evidence
o Not tell complainant and her niece to drop Robbery Case
o Court referred case to Executive Judge Luis M. Fontanilla of RTC
Dagupan for investigation. Case was then referred to Official of Court
Administrator for evaluation, report and recommendation. OCA adopted
Judge Fontillas’ findings and recommendation that all charges against
Judge Siapno be dismissed. Except for Ignorance of Law for failure to
award Civil Damages in 2 Criminal Cases – Siapno be fined P2,000.
o Investigating Judge found Complaint failed to present substantial
evidence to prove allegations.
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As to Judge Siapno failure to award Civil Damages in 2 Criminal Cases: o Hence, when no civil action is expressly instituted it shall be impliedly
o Records disclose both accused in cases pleaded Guilty to instituted with criminal action.
charges o It means that the civil action may be tried and prosecuted, with all the
o Criminal Case 1: P33.9k Repair on Damaged Property ancillary processes provided by law.
o Criminal Case 2: P34.7k and P15k Repair on Damaged Property
o Judge Siapno meted out a fine of P49.7k representing damages o Judge Siapno has been Administratively sanctioned 3 times before and
sustained by Offended Parties has obviously not reformed
o In justifying his omission to award civil damages, Judge Siapno alleges o More stringent penalties is warranted hence increase to P20k fine
prosecution did not present any evidence regarding Civil Aspect of case o Judge Siapno is found Guilty of Gross Ignorance of the Law and fined
P20k + stern warning
ISSUES
o W/N Judge Siapno is correct in not awarding Civil Damages – NO DISPOSITION
WHEREFORE, in view of all the foregoing, respondent Judge Orlando Ana F.
RULING & RATIO Siapno is found GUILTY of Gross Ignorance of the Law and is FINED the
o Judge Siapno should make a finding on the accused’s civil liability with amount of P20,000.00. He is also STERNLY WARNED that a repetition of
his rendition of Guilty verdict. It is basic that every person Criminally the same or similar offense in the future would be dealt with more severely.
Liable is also Civilly Liable.
o Article 2202 of Civil Code
o In crimes and quasi-delicts, the defendant shall be liable for all
damages which are the natural and probable consequences of
the act or omission complained of. It is not necessary that such
damages may have been foreseen or could have reasonably
been foreseen by the defendant.
o Sec 1 of RCP when complaint or information is filed without any
Allegation of Damages and Intention to prove and claim them, it is
understood that the Offended Party has Right to Prove and Claim for
them, Unless a Waiver or Reservation is made, or unless Offended Party
instituted Separate Civil Action.
o In such case the Civil Liability arising from Crime may be determined in
Criminal Proceedings. If Offended Party does not Waive to have it
Adjudged or does not Reserve Right to Institute a Separate Civil Action.
o If there is no Waiver or Reservation, then Evidence should be allowed to
Establish the extent of injuries suffered.
o Rules impose duty on courts to enter judgment with respect to Civil
Liability arising from offense. Even in case of acquittal, unless there is
clear showing that the act from which civil liability might arise did not
exist, judgment shall make a finding on Civil Liability of Accused in favor
of Offended Party.
o Hence – error for Judge Siapno not to have entered judgment with
respect to Civil Liability

o An offense causes two classes of injuries- first is social injury produced

by criminal act which is sought to be repaired thru imposition of
corresponding penalty, and second is personal injury caused to victim of
the crime which injury is sought to be compensated thru indemnity which
is civil in nature.
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