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Question
Facts: In a criminal case for estafa through swindling, the private offended party is a supplier who was defrauded by the accused in a supply contract. The supplier moves to intervene in the criminal action to pursue civil damages arising from the offense. The trial court denies the intervention on the ground that civil liability should be pursued by a separate civil action, not by intervention in the criminal case. The offended party appeals.
(a) Identify the controlling doctrine governing the intervention of a private offended party in criminal proceedings.
(b) Distinguish the two ways by which civil liability arising from the offense may be pursued in relation to a criminal case (intervention in the criminal case vs. separate civil action).
(c) Apply the doctrine to the facts: should the supplier be allowed to intervene in the criminal case to pursue civil damages? Briefly justify your conclusion and reference the practical consequences for the criminal proceedings.