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...

Facts:

Background of the Case

• Petitioner Meynardo L. Beltran and his wife Charmaine E. Felix were married on June 16, 1973, at the Immaculate Concepcion Parish Church in Cubao, Quezon City.
• After twenty-four years of marriage and having four children, petitioner initiated a petition for the declaration of nullity of marriage on February 7, 1997, alleging psychological incapacity under Article 36 of the Family Code.
• The petition for nullity was filed before Branch 87 of the Regional Trial Court (RTC) of Quezon City and was docketed as Civil Case No. Q-97-30192.

Allegations and Counterclaims

• In her Answer to the nullity petition, Charmaine E. Felix alleged that petitioner abandoned the conjugal home and cohabited with a woman named Milagros Salting.
• Subsequently, Charmaine Felix filed a criminal complaint for concubinage, under Article 334 of the Revised Penal Code, against petitioner and his alleged paramour.

Criminal Proceedings and Motion to Defer

• The criminal case was docketed as Criminal Case No. 236176 and was filed before the Metropolitan Trial Court of Makati City, Branch 61.
• On March 20, 1998, petitioner filed a Motion to Defer Proceedings Including the Issuance of the Warrant of Arrest in the criminal case, arguing that the pending nullity case presented a prejudicial question.
• Judge Alden Vasquez Cervantes denied the motion on August 31, 1998, and denied petitioner’s subsequent motion for reconsideration on December 9, 1998.

Petition for Review and Lower Court Orders

• Petitioner subsequently filed a petition for review, seeking to set aside the RTC Order dated January 28, 1999 (and the later Order dated February 23, 1999), which denied his prayer for the issuance of a writ of preliminary injunction aimed at enjoining the trial of Criminal Case No. 236176.
• In his petition, petitioner contended that the pending petition for nullity of marriage constitutes a prejudicial question that should suspend the criminal proceedings for concubinage.
• He argued that conflicting outcomes might arise—a final judgment negating the marriage in the civil case could potentially affect the criminal prosecution for concubinage, as it would imply that he was never legally married.

Petitioner’s Arguments Regarding Prejudicial Question

• Petitioner asserted that the determination of the nullity of his marriage is a necessary issue that would affect the criminal case’s determination, warranting the suspension of criminal proceedings.
• He argued that a divergent judicial determination in the civil case (declaring the marriage void) and in the criminal case (potential acquittal) might occur, thus justifying judicial intervention to ensure consistency.

Court’s Analysis on the Prejudicial Question

• The court clarified that for a civil case to be prejudicial to a criminal action, it must meet two essential elements:
• The civil case must involve an issue similar or intimately related to that raised in the criminal action.
• The resolution of the issue in the civil case must necessarily determine the guilt or innocence of the accused in the criminal case.
• The court noted that the civil case for the nullity of marriage does not satisfy the requirement because:
• The matter of nullity relates to the validity of the marriage rather than directly proving or disproving the facts constituting concubinage.
• Under Article 40 of the Family Code and relevant case law (e.g., Domingo vs. Court of Appeals), while a final judgment is required for purposes such as remarriage, evidence other than a final judgment may suffice in other disputes.
• The court emphasized that even if the marriage were later declared null, such a declaration would not serve as a defense against the concubinage charge, as the presumption remains that the marriage exists until legally nullified.

Conclusion of the Lower Court

• The lower court (RTC of Makati City, Branch 139) affirmed the denial of petitioner’s petition for certiorari seeking a writ of preliminary injunction.
• It ruled that the pendency of the civil nullity case does not pose a prejudicial question that would warrant the suspension of the ongoing criminal proceedings for concubinage.

Issue:

• Whether the pending petition for declaration of nullity of marriage raises a prejudicial question that justifies the suspension of the criminal proceedings for concubinage.
• Whether the issues raised in the civil nullity case are sufficiently similar or intimately related to those in the criminal case such that the outcome of one would necessarily predetermine the outcome of the other.
• Whether the potential for conflicting judicial determinations between the civil and criminal cases (i.e., a declaration of nullity versus a conviction for concubinage) warrants judicial intervention to suspend the criminal proceedings.
• Whether petitioner’s contention that a declaration of nullity (and thus the assertion that his marriage never validly existed) would automatically absolve him from prosecution for concubinage is legally tenable.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)