CASE DIGEST ON REYES V. SEMPIO-DY

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CASE DIGEST ON REYES V. SEMPIO-DY [141 S 208 (1986)] - Where the private complainant in an information for intrigu-ing against honor was represented by a private prosecutor but defendant pleaded guilty and was sentenced to a fine, a civil case damages is will prosper despite the lack of reservation and the intervention of a private prosecutor, because there was no opportunity to present evidence by reason of the unexpected plea of guilty.
Roa v. De La Cruz is not applicable because in that case, there was a full-blown hearing where a private prosecutor participatedly actively but failed to present evidence to support the claim for damages. Hence, a civil action could not prosper. Furthermore, under Art. 33, there is no require¬ment for reseervation to file an independent civil action arising from defamation.

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