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Eduardo Cojuangco, Jr. Vs. Court Of Appeals, Et Al.

EDUARDO COJUANGCO, JR. and GRETCHEN OPPN-COJUANGCO, petitioners, vs. THE HONORABLE COURT OF APPEALS, GEORGE F. SISON and LUIS R. MAURICIO, respondents. Angara, Abello, Concepcion, Regala and Cruz for petitioners. Jalandoni, Cope & Suarez for private respondent. Sison, Dominguez & Associates for respondents.

G.R. No. L-37404 | 1991-11-18

D E C I S I O N


DAVIDE, JR., J.:

May a criminal case for libel and an independent civil action for damages arising therefrom, filed pursuant to Article 33 of the Civil Code, be consolidated for joint trial?

The case which provoked this issue eighteen (18) years ago was then one of first impression. However, its early resolution did not seem to merit priority from the parties and so it became one of the many "move in the premises" cases of this Court.

Subsequent events had significantly dimmed the glow of the issue's novelty.

In the 1982 case of Caños vs. Peralta, et al., 1 this Court enunciated a new doctrine which...