Case Digest (G.R. No. 20435)
Facts:
In Beltran vs. People, petitioner Meynardo L. Beltran and his spouse Charmaine E. Felix contracted marriage on June 16, 1973 at the Immaculate Concepcion Parish Church in Cubao, Quezon City, and begot four children. On February 7, 1997, petitioner filed Civil Case No. Q-97-30192 for declaration of nullity of marriage under Article 36 of the Family Code, alleging his wife’s psychological incapacity before Branch 87 of the Regional Trial Court of Quezon City. In response, Charmaine Felix accused Beltran of abandoning the conjugal home to cohabit with Milagros Salting and then initiated Criminal Case No. 236176 for concubinage under Article 334 of the Revised Penal Code before the Metropolitan Trial Court of Makati City, Branch 61. After a September 16, 1997 resolution finding probable cause, an information was filed. On March 20, 1998, to avert arrest, Beltran moved to defer proceedings and the issuance of a warrant, invoking the pendency of his nullity action as a prejudicial queCase Digest (G.R. No. 20435)
Facts:
- Marriage and Petition for Nullity
- Petitioner Meynardo L. Beltran and respondent Charmaine E. Felix married on June 16, 1973 at Immaculate Concepcion Parish Church, Cubao, Quezon City, and had four children.
- On February 7, 1997, petitioner filed a petition for nullity of marriage under Article 36 (psychological incapacity) of the Family Code before RTC, Branch 87, Quezon City (Civil Case No. Q-97-30192).
- Allegations in Civil Case and Initiation of Criminal Proceedings
- In her Answer, Charmaine Felix alleged petitioner abandoned the conjugal home and cohabited with Milagros Salting.
- Charmaine filed a criminal complaint for concubinage under Article 334 of the Revised Penal Code before the Makati City Prosecutor, which on September 16, 1997 found probable cause and lodged Information in MTC, Branch 61 (Criminal Case No. 236176).
- Motions to Defer and Lower Court Proceedings
- On March 20, 1998, petitioner moved to defer proceedings (including issuance of an arrest warrant) in the concubinage case, arguing the nullity petition posed a prejudicial question; MTC Branch 61 denied the motion on August 31, 1998, and denied reconsideration on December 9, 1998.
- Petitioner filed a certiorari petition with RTC, Branch 139, Makati City to enjoin the criminal trial; RTC denied relief in an Order dated January 28, 1999, and again denied reconsideration on February 23, 1999.
- Petition for Review
- Petitioner filed a Rule 45 petition before the Supreme Court seeking reversal of RTC Branch 139’s January 28, 1999 Order denying preliminary injunction.
Issues:
- Whether the pendency of the civil petition for nullity of marriage constitutes a prejudicial question that warrants suspension of the criminal case for concubinage.
- Whether the possibility of conflicting outcomes in the nullity and concubinage proceedings justifies deferral of the criminal trial.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)