Case Summary (G.R. No. 257219)
Petitioner
The People of the Philippines, represented by the Office of the Solicitor General, seeks reversal of the Court of Appeals’ affirmation of the dismissal of criminal cases for falsification against the respondents.
Respondents
Camilo Camenforte and Robert Lastrilla, charged with falsification of public documents under Articles 171 and 172 of the Revised Penal Code.
Key Dates
- December 7, 1985: Execution of three deeds of sale by spouses Rafael and Aurora Granda
- June 1989 and September 16, 2000: Deaths of Rafael and Aurora Granda
- February 28, 2000: Registration of deeds of sale
- August 21, 2001: Filing of civil case for nullification of titles (RTC-Branch 9)
- June 6, 2005: RTC decision dismissing civil case
- October 26, 2007: Finality of CA resolution in the civil case
- January 30, 2008 to December 15, 2008: Motions to quash and arraignments in criminal cases (RTC-Branch 8)
- April 27, 2015 and September 23, 2015: Court of Appeals’ Decision and Resolution denying the People’s appeal
- June 14, 2021: Supreme Court Decision
Applicable Law
- 1987 Philippine Constitution
- Rules of Court: Rule 45 (Certiorari), Rule 39 § 47 (Res judicata), Rule 111 §§ 6–7 (Prejudicial Question)
- Revised Penal Code: Articles 171 (Falsification by public officer or employee) and 172 (Falsification by private individual)
- Civil Code: Article 33 (Independence of criminal and civil actions)
Factual Background
Spouses Rafael and Aurora Granda allegedly executed three deeds of sale on December 7, 1985, transferring multiple parcels of land to the Uy siblings and Robert Lastrilla. Fifteen years later, these deeds were annotated and titles reissued in the vendees’ names. After Aurora’s death, heirs discovered the deeds were antedated and signatures purportedly forged. PNP-Crime Laboratory reports suggested mismatched and similar stroke structures between the grandparents’ and Silvina’s signatures.
Civil Nullification Proceedings
In August 2001, Benjamin and Blanquita filed Civil Case No. 2001-09-135 before RTC-Branch 9, alleging forgery and seeking nullification of titles. On June 6, 2005, the court dismissed the complaint for lack of proof, finding the signatures genuine and upholding the presumption of due execution. The Court of Appeals affirmed, and its resolution became final on October 26, 2007.
Criminal Prosecutions and Motions to Dismiss
The Office of the City Prosecution filed informations against Camenforte and Silvina for forgery (Criminal Cases 2001-07-482 to 484) and against Lastrilla for falsification (Criminal Cases 2008-03-109 to 111). Respondents moved to quash these informations on grounds of res judicata and prejudicial question, which RTC-Branch 8 granted on August 20, 2009, citing the final civil judgment on the deeds’ genuineness. The CA denied the People’s appeal on April 27, 2015, and its resolution was affirmed on September 23, 2015.
Issues Presented
- Whether the pending criminal cases are barred by res judicata due to the final civil decision on the deeds’ validity.
- Whether a prejudicial question arising from the civil case’s factual finding bars further criminal prosecution.
Res Judicata Analysis
Res judicata requires: final judgment on the merits, jurisdiction, and identity of parties, subject matter, and cause of action. The Supreme Court held that the People, not a party to the civil case, could not be bound by its findings. The prosecutorial interest in criminal cases differs from an heir’s interest in civil nullification. There was no complete identity of parties or cause of action, so res judicata does not bar the criminal prosecutions.
Prejudicial Question Doctrine
A prejudicial question exists when a prior decision on an issue is a logical antecedent to, and determinative of, a subsequent action. Under Rule 111, §§ 6–7, the civil action need not strictly precede the criminal action so long as the factual finding is “intimately related” and its resolution determines whether the criminal case may proceed. Our jurisprudence treats the sequence of filing as directory, emphasizing instead whether the issue in the civil case conc
...continue readingCase Syllabus (G.R. No. 257219)
Facts
- On December 7, 1985, spouses Aurora and Rafael Granda executed three deeds of sale covering seven parcels of land: two deeds (TCT Nos. T-249, T-1312 and T-816) sold to the Uy siblings for ₱8,800,000.00 and one deed (TCT No. 6736) sold to Robert Lastrilla for ₱200,000.00.
- Approximately 15 years later, the first two deeds were annotated and re-registered in the vendees’ names; the third deed lacked annotation due to a missing title record.
- Aurora died in September 2000; Rafael had died in June 1989. Five months after Aurora’s death, grandson Rafael A. Granda filed criminal charges for forgery, alleging the 1985 deeds were actually executed in 1999–2000 and antedated.
- The PNP-Crime Laboratory compared signatures and concluded that the grandparents’ signatures on the deeds were not genuine and bore similarities to Silvina Granda’s handwriting.
- Silvina Granda and notary public Camilo Camenforte were charged under Article 171 (falsification); Robert Lastrilla was charged under Article 172 (causing falsification).
- Meanwhile, heirs Benjamin R. Granda and Blanquita R. Serafica filed Civil Case No. 2001-09-135 seeking nullification of the deeds and titles, alleging the same forgery and requesting reconveyance of properties.
Procedural History
- The city prosecutor initially dismissed complaints against Lastrilla and the Uy siblings; DOJ review found probable cause against Lastrilla.
- Criminal informations were filed: Nos. 2001-07-482 to 484 against Camenforte and Silvina (Articles 171 §§1, 2, 5) and Nos. 2008-03-109 to 111 against Lastrilla (Article 172).
- RTC-Branch 9 in Civil Case No. 2001-09-135 dismissed the civil complaint, finding the deeds genuine; the CA affirmed.
- Respondents moved to quash/dismiss the criminal cases on grounds of res judicata and prejudicial question; RTC-Branch 8 granted their motions in August 2009.
- The CA, in decisions dated April 27, 2015 and September 23, 2015, affirmed the RTC dismissal.
- The People filed a Rule 45 petition for certiorari before the S