Title
Purisima vs. Solis
Case
G.R. No. L-27172
Decision Date
Jan 31, 1972
Angel Campoy faced civil, administrative, and criminal cases for alleged fraud and falsification in a land deed. The Supreme Court dismissed moot issues, emphasizing prompt resolution of criminal case 7894.
Font Size:

Case Digest (G.R. No. L-27172)

Facts:

Background of the Case:

  • On June 3, 1959, respondent Angel Campoy executed a "Deed of Extrajudicial Settlement and Sale" involving a parcel of land in barrio Looc, Sibulan, Negros Oriental. The deed purported to settle ownership among the heirs of Macaria Grifo and transferred ownership to Campoy and his wife.

Civil Case 3907:

  • On May 31, 1961, civil case 3907 was filed against Campoy in the Court of First Instance of Negros Oriental. The plaintiff alleged that Campoy committed fraud by omitting Esperanza Abol, a legitimate heir, from the deed.

Administrative Case:

  • In March 1961, an administrative case was filed against Campoy, then City Judge of Dumaguete, for falsification of the same deed. It was alleged that Campoy deleted an heir's name, falsified residence certificates, and notarized the deed. A judge found Campoy guilty, and on December 3, 1965, President Diosdado Macapagal ordered his removal. However, the order was reconsidered after a change in administration in 1966.

Criminal Case 7894:

  • On February 15, 1966, the provincial fiscal filed criminal case 7894 against Campoy for falsification, the same offense in the administrative case. The case was assigned to Judge Cipriano Vamenta, Jr.

Motion to Suspend Civil Case:

  • On April 21, 1966, Campoy moved to suspend civil case 3907 pending the outcome of criminal case 7894, arguing that the fraud alleged in both cases was the same. The trial court granted the motion.

Motion to Set Criminal Case for Trial:

  • The private prosecutor and provincial fiscal moved to set criminal case 7894 for trial. Campoy opposed, citing the pendency of the civil and administrative cases as prejudicial. Judge Vamenta suspended the criminal case on December 16, 1966, pending the resolution of civil case 3907.

Supervening Events:

  • On March 14, 1967, President Ferdinand Marcos exonerated Campoy of the administrative charges. Campoy then moved to set criminal case 7894 for trial, which the judge granted on April 20, 1967, despite opposition from the provincial fiscal.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Mootness Doctrine: The Court applied the mootness doctrine, as the respondent judge's order to set the criminal case for trial rendered the petition unnecessary.
  2. Prejudicial Question: The Court did not rule on whether the civil case posed a prejudicial question to the criminal case, as the issue became moot.
  3. Judicial Ethics: The Court refrained from addressing the ethical concerns raised by the petitioner, as there was no clear evidence of misconduct by Campoy or his counsel.
  4. Expeditious Resolution: The Court emphasized the importance of resolving criminal cases promptly to avoid unnecessary delays.


Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.