G.R. No. 203287 - Domingo vs. Spouses Singson

The Spouses Macario C. Domingo and Felicidad S.D. Domingo (Spouses Domingo) were the owners of a parcel of land covered by Transfer Certificate of Title (TCT) No. 32600 (23937) 845-R, located at F. Sevilla Street, San Juan, Metro Manila, along with a house built thereon.
Macario Domingo died on February 22, 1981, and Felicidad Domingo died on September 14, 1997.
They were survived by several heirs, including respondent Engracia D. Singson and petitioners Renato S.D. Domingo and his co-heirs, namely Consolacion D. Romero, Josefina D. Borja, and Rafael, Ramon, and Rosario Domingo.

On June 6, 2006, an Absolute Deed of Sale purportedly made by the Spouses Domingo conveyed the subject property to Engracia D. Singson, who then registered the property under TCT No. 12575 issued in her name.
The petitioners discovered this sale only upon receiving summons related to an ejectment/unlawful detainer case filed by Engracia on September 26, 2006, docketed as Civil Case No. 9534 in the Metropolitan Trial Court (MTC) of Manila, against Consolacion, Rosario, Rafael, and Ramon.
The petitioners denied the validity of the sale, alleging the signatures of their deceased parents on the Absolute Deed of Sale were forgeries.

On July 31, 2006, petitioners filed a complaint for nullity of the sale based on forgery before the Regional Trial Court (RTC) of Pasig City, docketed as Civil Case No. 70898 and assigned to Branch 160.

On February 28, 2007, Renato, Consolacion, and Ramon filed a complaint with the Office of the City Prosecutor (OCP) of Pasig City charging Engracia with falsification of public documents, estafa, and use of falsified documents.
May 6, 2008, the OCP filed an Information with the RTC charging Engracia and her husband Manuel F. Singson with estafa through falsification of public documents, docketed as Criminal Case No. 137867 and assigned to Branch 264 of the RTC.
On July 11, 2008, the Spouses Singson filed a motion to suspend the criminal proceedings on the ground of a prejudicial question, in reference to the pending Civil Case No. 70898 concerning the validity of the Absolute Deed of Sale.
The private prosecutor opposed the motion, asserting that the criminal case could proceed independently.
On February 12, 2010, the RTC granted the motion to suspend criminal proceedings, which was later affirmed following a motion for reconsideration denied on June 7, 2011.

The petitioners filed a petition for certiorari before the Court of Appeals (CA) (CA-G.R. SP No. 122054) seeking to annul the RTC’s suspension order.
On August 31, 2012, the CA denied the petition, ruling the suspension was proper due to the presence of a prejudicial question.

Civil Case No. 70898 experienced numerous resets and delays in pre-trial conferences from February 2008 to 2011, partly due to substitution motions and changes in presiding judges.
Petitioners and their counsel repeatedly failed to appear during scheduled pre-trial hearings without valid justification.
On July 29, 2011, the RTC Branch 264 dismissed the complaint due to failure to prosecute under Section 5, Rule 18 of the Rules of Court.
Petitioners appealed the dismissal to the CA (CA-G.R. CV No. 98026), asserting the dismissal was improper and Engracia’s motion to dismiss was defective.
On June 28, 2013, the CA affirmed the dismissal of the complaint.

Whether the suspension of the criminal proceedings in Criminal Case No. 137867 on the ground of a prejudicial question was proper.
Whether the dismissal of the petitioners’ civil complaint in Civil Case No. 70898 due to failure to prosecute was proper.