Question juridique clé
Whether the dismissal of civil claims against only one of several solidary defendants in a criminal adhesion proceeding is a principal judgment under Art. 58 OG.
Solution extraite
Yes. A final determination of the civil claim against one defendant is a principal judgment even if the same claim remains pending against another solidary co-defendant.
Motifs extraits
Although a principal judgment generally exists only when all claims in dispute are resolved, an exception has long been recognized in cases with multiple defendants: an appeal is admissible as soon as the claims directed against the defendant concerned are definitively decided. In criminal adhesion proceedings involving spouses, the procedural situation is even clearer because there is no joinder of defendants in the civil sense; formally the claims are separate, and materially each debtor is liable individually, albeit solidarily.