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In a criminal case for estafa through misappropriation, the private offended party, a supplier defrauded by the accused, 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. Which statement best describes the controlling doctrine on intervention of a private offended party in criminal proceedings and the available modes of pursuing civil liability arising from the offense?