Joselito R.

Pimentel, Petitioner
V
Maria Chrysantine L. Pimentel and People, Respondents

Facts:

Maria Chrysantine L. Pimentel filed an action for frustrated parricide against the Joselito Pimentel
(petitioner). Several months after, the private respondent filed an action for the declaration of nullity of
their marriage. The petitioner filed an urgent motion to suspend the proceedings with the court where
the criminal case was pending on the ground of existence of a prejudicial question. The petitioner
asserted that since the relationship between the offender and the victim is a key element in parricide,
the outcome of the civil case would have a bearing in the criminal case against him.

When the case reached the CA, the court concluded against the existence of a prejudicial question. The
CA ruled that, in the criminal case for frustrated parricide, the issue is whether the offender commenced
the commission of the crime of parricide directly by overt acts and did not perform all the acts of
execution by reason some cause or accident other than his own spontaneous desistance. On the other
hand, the issue in the civil action for annulment of marriage is whether the petitioner is psychologically
incapacitated to comply with the essential marital obligations.

The CA continued that, even if the marriage between petitioner and respondent would be declared void,
it would be immaterial to the criminal case because prior to the declaration of nullity, the alleged acts
constituting the crime of frustrated parricide had already been committed and all that us required for
the charge of frustrated parricide is that, at the time of the commission of the crime, the marriage is still
subsisting.

Issue:

Whether or not a prejudicial question is existing in the case.

Ruling:

The SC sustained the conclusion of the CA with an added reason – that the facts show that the criminal
case was filed ahead of the case for declaration of nullity. The rule is clear that for a prejudicial question
to exist, the civil action must be instituted first before the filing of the criminal action. As such, the
requirement of Sec. 7, Rule 111 of the rules on Criminal Procedure was not met since the civil action was
filed subsequent to the filing of the criminal action.

The Court added that the resolution of the civil action is not a prejudicial question that would warrant
the suspension of the criminal action. While the relationship between the offender and the victim is a
key element in the crime of parricide, the issue in the civil case is not similar or immediately related to
the issue in the criminal case for parricide.

Renato S.D. Domingo, petitioner

V
Spouses Engracia D. Singson and Manuel F. Singson, Respondents

Facts:
Spouses Macario and Felicidad Domingo are the parents of respondent Engracia Singson and petitioners
Renato Domingo and his co-heirs whom he represents herein. During the lifetime of the spouses, they
owned a parcel of land covered by Transfer Certificate of Title No. 32600 (23932) 845-R and the subject
property is built thereon. Macario died in 1981 and Felicidad died in 1997.

In 2006, Engracia filed with the Metropolitan Trial Court of Manila a complaint for ejectment/unlawful
detainer against her siblings, Consolacion, Rosario, Rafael, and Ramon. She claimed that she is the
absolute owner of the subject property, having bought the same from their parents as evidenced by an
Absolute Deed of Sale. The petitioners learned of the supposed subject sale of the subject property
when they received summons and a copy of Engracia’s complaint in Civil Case No. 9534.

Consequently, the petitioners filed a complaint with the RTC which sought the nullity of sale alleging
that the Absolute of Deed of Sale was a nullity since the signatures of their parents appearing thereon as
the supposed vendors were forged. In 2007, a Joint Affidavit Complaint was filed by Renato,
Consolacion, and Ramon claiming that Engracia falsified the signatures of their parents in the Absolute
Deed of Sale thus, charging them with falsification of public document, estafa, and use of falsified
documents.

In 2008, the spouses filed a Motion to Suspend Proceedings Due to Prejudicial Question with the RTC
claiming that the validity and genuineness of the Absolute Deed of Sale are determinative of their guilt
of the crimes charged. The RTC granted the motion to suspend the proceedings filed by Engracia and her
husband. Hence, this petition.

Issues:

1. Whether the proceedings in the criminal case were properly suspended on the ground of
prejudicial question.
2. Whether the dismissal of the petitioners’ complaint in civil case due to failure to prosecute was
proper.

Ruling:

1. Based on the concepts of a prejudicial question. There is indeed appears to be a prejudicial

question in the case. The allegation in the civil case is based on the very same facts, which would
necessarily determinative of their guilt or innocence as accused in the criminal case. If the
signatures of the spouses Domingo in the Absolute Deed of Sale are genuine, then there would
be no falsification and the Spouses Singson would be innocent of the offenses charged.
Otherwise, if the criminal procedure was allowed to proceed ahead, that would be a gross
injustice and it would be prejudicial to the spouses Singson if indeed their signature are
authentic.

The petitioners’ reliance on independent civil actions finds no application in this case because it
is clear that the civil case is relevant to the proceedings of the criminal case. The genuineness of
the signature of the Supreme Court of the Spouses Domingo appearing in the Absolute Deed of
Sale is intimately related to the change of estafa through falsification of public document in the
criminal case. The resolution of the main issue in the civil case would necessarily be
determinative of the guilt or innocence of the Spouses Singson.
2. Yes. During the scheduled pre-trial, the petitioners and their counsel failed to appear without
informing the RTC of the reason for their non-appearance. Clearly, the petitioners’ disregard of
scheduled pre-trial indeed justified the dismissal of their complaint. The procedural rules are not
to be disregarded or dismissed simply because their non-observance may have resulted in
prejudice to a party’s substantive rights. The petitioners have not shown any persuasive reason,
which would justify a relaxation of the rules on pre-trial. Hence, the civil case had already been
dismissed and there is no longer any prejudicial question in the criminal case therefore, it is
directed to proceed.