Case Digest (G.R. No. 137567)
Facts:
The case involves Meynardo L. Beltran as the petitioner and the People of the Philippines, along with Hon. Judge Florentino A. Tuazon, Jr., as the respondents. The events leading to this case began with the marriage of Meynardo Beltran and Charmaine E. Felix on June 16, 1973, at the Immaculate Concepcion Parish Church in Cubao, Quezon City. After twenty-four years of marriage and having four children, on February 7, 1997, Beltran filed a petition for nullity of marriage based on psychological incapacity under Article 36 of the Family Code. This petition was filed in Branch 87 of the Regional Trial Court of Quezon City and was docketed as Civil Case No. Q-97-30192. In her response, Charmaine Felix claimed that Beltran had abandoned their home and was living with another woman, Milagros Salting. Subsequently, she filed a criminal complaint for concubinage against Beltran and Salting, which led to the filing of Criminal Case No. 236176 in the Metropolitan Trial Court of Makati C...
Case Digest (G.R. No. 137567)
Facts:
Marriage and Family Background:
- Petitioner Meynardo Beltran and Charmaine E. Felix were married on June 16, 1973, at the Immaculate Concepcion Parish Church in Cubao, Quezon City. They had four children during their 24-year marriage.
Petition for Nullity of Marriage:
- On February 7, 1997, Beltran filed a petition for nullity of marriage under Article 36 of the Family Code (psychological incapacity) before the Regional Trial Court (RTC) of Quezon City, docketed as Civil Case No. Q-97-30192.
Allegations of Abandonment and Concubinage:
- In her Answer to the petition, Charmaine alleged that Beltran abandoned the conjugal home and cohabited with Milagros Salting. She subsequently filed a criminal complaint for concubinage under Article 334 of the Revised Penal Code against Beltran and Salting.
Criminal Case for Concubinage:
- The City Prosecutor's Office of Makati found probable cause and filed an Information against Beltran and Salting. The case was docketed as Criminal Case No. 236176 and assigned to the Metropolitan Trial Court (MeTC) of Makati City, Branch 61.
Motion to Defer Proceedings:
- On March 20, 1998, Beltran filed a Motion to Defer Proceedings, arguing that the pending civil case for nullity of marriage constituted a prejudicial question to the criminal case. Judge Alden Cervantes denied the motion on August 31, 1998, and the motion for reconsideration was likewise denied on December 9, 1998.
Petition for Certiorari and Injunction:
- Beltran filed a petition for certiorari before the RTC of Makati City, Branch 139, seeking to enjoin the criminal proceedings. The RTC denied the petition on January 28, 1999, and the motion for reconsideration was also denied on February 23, 1999.
Petition for Review:
- Beltran elevated the case to the Supreme Court, arguing that the civil case for nullity of marriage posed a prejudicial question to the criminal case for concubinage.
Issue:
- Whether the pendency of the civil case for nullity of marriage constitutes a prejudicial question that warrants the suspension of the criminal case for concubinage.
- Whether the possibility of conflicting rulings in the civil and criminal cases justifies the suspension of the criminal proceedings.
Ruling:
The Supreme Court dismissed the petition for lack of merit. The Court held that the pendency of the civil case for nullity of marriage does not constitute a prejudicial question to the criminal case for concubinage.
Ratio:
Prejudicial Question Requirements:
- A prejudicial question exists when:
(a) the civil action involves an issue similar or intimately related to the issue raised in the criminal action; and
(b) the resolution of such issue determines whether or not the criminal action may proceed.
- A prejudicial question exists when:
No Prejudicial Question in This Case:
- The civil case for nullity of marriage does not determine Beltran's guilt or innocence in the criminal case for concubinage. Even if the marriage is later declared void, it does not absolve Beltran of liability for concubinage committed before the judicial declaration of nullity.
Judicial Declaration of Nullity Required:
- Under Article 40 of the Family Code, the absolute nullity of a marriage must be declared by a final judgment. Until such a declaration is made, the marriage is presumed valid, and parties cannot unilaterally judge its nullity.
Risk of Prosecution:
- Beltran assumed the risk of being prosecuted for concubinage by cohabiting with another woman before obtaining a judicial declaration of nullity of his marriage.
Avoiding Conflicting Decisions:
- The possibility of conflicting rulings in the civil and criminal cases does not justify suspending the criminal proceedings. The criminal case can proceed independently, and evidence of nullity can be presented in the criminal trial.
Conclusion:
The Supreme Court affirmed the lower courts' rulings, holding that the civil case for nullity of marriage does not pose a prejudicial question to the criminal case for concubinage. The petition was dismissed for lack of merit.