Chantango v. Abaroa - 218 U.S. 476 (1910)
U.S. Supreme Court
Chantango v. Abaroa, 218 U.S. 476 (1910)
Chantango v. Abaroa
Submitted October 24, 1910
Decided November 28, 1910
218 U.S. 476
The general rule of the common law is that a judgment in a criminal proceeding cannot be read in evidence in a civil action to establish any fact there determined. The parties are not the same and different rules of evidence are applicable.
Identity of parties will not always operate to make a judgment in a criminal action admissible in a civil action; there must be identity of issue, Stone v. United States, 167 U. S. 178, although, as held in Coffey v. United States, 116 U. S. 436, when the facts are ascertained in a criminal case as between the United States and the defendant, they cannot be again litigated as between him and the United States as the basis of any statutory punishment denounced as a consequence of the existence of the facts.
In a case coming from the Philippine Islands, however, this Court will not apply the common law rule as to effect to be given in a subsequent civil case to a judgment in a criminal case, but will consider only whether the local law of the Philippine Islands has been rightly applied.
The local law in the Philippine Islands, which is still in force, not having been suspended by legislation, is that indemnity for damages in penal cases is a consequence of the commission of the crime and a verdict of acquittal carries with it exemption from civil liability. This rule applies even against one who in the criminal action attempted to reserve his rights to bring a civil action.
The facts, which involve the right of recovery in the Philippine Islands of damages caused by alleged criminal
acts of defendant in a civil action after the defendant's acquittal in a criminal action, are stated in the opinion.