5/28/2020 E-Library - Information At Your Fingertips: Printer Friendly [12] Id. at 154-156, (the bold underscoring is in the original text). [13] People v. Bensig, G.R. No. 138989, September 17, 2002, 389 SCRA 182, 194. [14] Article 8 of the Revised Penal Code. [15] E.g., Article 100 of the Revised Penal Code stipulates that every person criminally liable for a felony is also civilly liable. The provision, although seemingly applicable only to a felony, governs also a non-felony by virtue of Article 10 of the Revised Penal Code expressly making the provisions of the Revised Penal Code “supplementary” to special laws unless such laws provide otherwise. [16] Article 104 of the Revised Penal Code. [17] Section 1, Rule 111 of the Rules of Court (2000). [18] The Civil Code, in its Article 1170, expressly holds to be liable for damages those who in the performance of their obligations are guilty of fraud, negligence, or delay, and those who in any manner contravene the tenor of the obligations; and in its Article 1171, considers the responsibility arising from fraud to be demandable in all obligations. [19] G.R. No. 206236, July 15, 2013, 701 SCRA 229 (the bold underscoring is part of the original text of the decision). [20] Id. at 239-240. [21] The Civil Code states: Article 1207. The concurrence of two or more creditors or of two or more debtors in one and the same obligation does not imply that each one of the former has a right to demand, or that each one of the latter is bound to render, entire compliance with the prestation. There is a solidary liability only when the obligation expressly so states, or when the law or the nature of the obligation requires solidarity. (1137a) See IV Tolentino, Commentaries and Jurisprudence on the Civil Code of the Philippines, 1991 (Reprinting 1999), Central Lawbook Publishing Co., Inc., Quezon City, p. 220. [22] Malvar v. Kraft Food Phils., Inc., G.R. No. 183952, September 9, 2013; Chan, Jr. v. Iglesia ni Cristo, Inc., G.R. No. 160283, October 14, 2005, 473 SCRA 177, 186. [23] Black’s Law Dictionary, Fifth Edition, 1979, pp. 752-753, citing Bowen v. Iowa Nat. Mut. Ins. Co., 270 N.C. 486, 155 S.E. 2d 238, 242. [24] G.R. No. 130068, October 1, 1998, 297 SCRA 30, 84. elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/57144 11/12