Title
Te vs. Court of Appeals
Case
G.R. No. 126746
Decision Date
Nov 29, 2000
Arthur Te married Liliana Choa in 1988, separated, and married Julieta Santella in 1990 while still legally married. Choa filed bigamy charges; Te sought annulment, alleging fraud. Courts ruled against Te, upholding bigamy charges and denying suspension of proceedings, as the annulment case did not affect the bigamy charge's validity.
motion to suspend
criminal proceedings
administrative proceedings

Case Summary (G.R. No. 126746)

Factual Background

Petitioner and private respondent contracted a civil marriage on September 14, 1988 but did not live together thereafter, although they met regularly. Private respondent bore a daughter on April 21, 1989. Petitioner ceased visiting private respondent soon after. While the first marriage was allegedly still subsisting, petitioner contracted a second marriage with Julieta Santella on May 20, 1990. Upon learning of that marriage, private respondent filed a complaint-affidavit, which culminated in the filing of an information for bigamy against petitioner in RTC Branch 98. Petitioner, for his part, filed an action for annulment of his marriage to private respondent alleging force, concealment of pregnancy, and psychological incapacity. Private respondent later initiated an administrative complaint before the PRC seeking revocation of petitioner’s engineering license and of Santella’s license, alleging acts of immorality and falsification.

Trial Court Proceedings

Criminal Case No. Q-90-14409 for bigamy proceeded in RTC Branch 98. After the prosecution rested, petitioner moved for leave to file a demurrer to evidence and filed a motion to inhibit the trial judge, Judge Cezar C. Peralejo, alleging antagonism toward petitioner’s counsel. The trial court denied the demurrer to evidence in an order dated November 28, 1990, finding a prima facie case against petitioner. The motion to inhibit was likewise denied for lack of legal basis. In the civil petition for annulment, petitioner sought a judicial declaration of nullity of his marriage; that action remained pending while criminal and administrative proceedings were ongoing.

Proceedings Before the PRC Board and the Court of Appeals

Petitioner sought suspension of the administrative proceedings before the PRC Board on the ground that the annulment and criminal cases were prejudicial questions. The PRC Board denied the motion on July 16, 1991. Petitioner filed two petitions for certiorari with the Court of Appeals: CA-G.R. SP No. 23971 challenging the RTC’s denial of the demurrer to evidence and the denial of the motion to inhibit; and CA-G.R. SP No. 26178 attacking the PRC Board’s denial of the motion to suspend administrative proceedings. The Court of Appeals consolidated the petitions and, in its Decision of August 31, 1994, affirmed the RTC’s and PRC Board’s rulings, finding no grave abuse of discretion. The Court of Appeals denied petitioner’s motion for reconsideration by Resolution dated October 18, 1996.

Issues Presented to the Supreme Court

Petitioner presented three principal issues: whether the Court of Appeals erred in refusing to suspend the criminal and administrative proceedings despite the pendency of the civil annulment action; whether the Court of Appeals gravely abused its discretion in upholding the trial court’s denial of petitioner’s demurrer to evidence; and whether the Court of Appeals committed legal error in refusing to hold that Judge Peralejo should have inhibited himself for alleged antagonism and bias.

Supreme Court Disposition

The Supreme Court denied the petition for lack of merit. The Court observed that the termination of Civil Case No. Q-90-6205 for annulment rendered the question of suspension moot and academic but nevertheless addressed the doctrine of prejudicial question. The Court upheld the conclusions of the Court of Appeals and the RTC that no prejudicial question existed to warrant suspension of the criminal or administrative proceedings, that denial of the demurrer to evidence did not constitute an adjudication on the merits, and that the motion to inhibit did not demonstrate bias sufficient to deprive petitioner of a fair trial.

Prejudicial Question Doctrine and Its Application

The Court reviewed the definition and rationale of a prejudicial question, namely a civil issue distinct from but so intimately connected to the crime that its resolution would necessarily determine guilt or innocence. The Court concluded that the pendency of petitioner’s annulment action did not raise such a question because bigamy requires only that a prior marriage be subsisting at the time of the subsequent marriage. The Court stressed that under Article 40, Family Code, the absolute nullity of a previous marriage may not be invoked for purposes of remarriage unless there is a final judgment declaring such marriage void. The Court noted that prior decisions cited by petitioner that recognized judicial decree as unnecessary for invalid marriages were no longer controlling. The Court therefore held that, at the time the alleged bigamous marriage was contracted, the first marriage was presumed valid until judicially annulled, so the annulment action did not necessarily determine petitioner’s criminal liability.

Administrative Proceedings and Section 32 of PRC Rules

The Court addressed the interplay between administrative and criminal or civil proceedings. It affirmed that the PRC Board properly proceeded with the administrative investigation because Section 32 of the Rules and Regulations Governing the Regulation and Practice of Professionals expressly provides that administrative proceedings shall not be suspended by the filing or pendency of criminal or civil cases involving the same facts. The Court also observed that the administrative complaint against petitioner encompassed charges beyond the alleged bigamous marriage, including immoral conduct for failure to perform marital and parental obligations and for cohabitation.

Demurrer to Evidence: Standard and Application

The Court reiterated the standard governing demurrers to evidence and the deference due to the trial court’s exercise of discretion. The Court noted that the denial of a demurrer is not subject to reversal absent grave abuse of discretion. The RTC denied petitioner’s demurrer after finding a prima facie case for bigamy, and the Court of Appeals found no grave abuse. The Supreme Court emphasized that the denial of a demurrer on the ground of a prima facie case is not an adjudication on the merits but an evaluation of the prosecution’s evidence to determine whether a full trial is necessary. The Court invoked Section 15, Rule 119 to underscore that the accused’s remedy is to present evidence in defense during trial.

Motion to Inhibit and the Standard for Judicial Disqualification

The Court examined petitioner’s allegations that Judge Peralejo exhibited antagonism and prejudgment in several remarks and rulings. The Court applied Section 1, Rule 137, which lists disqualifying circumstances and allows a judge, in the exercise of sound discretion, to disqualify himself for just and valid reasons other than those enumerated. The Court held that mere suspicion of partiality is insufficient; there must be clear and convincing evidence of bias. Citing precedent, the Court co

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