FACTS:
This case is a special civil action for certiorari to set aside orders of the trial court denying the petitioners' motion for the suspension of their arraignment in a criminal case for violation of the Anti-Squatting Law. The criminal case was filed against petitioners for unlawfully occupying a portion of private respondent's property without her knowledge and consent. Petitioners sought the suspension of their arraignment on the ground that there was a prejudicial question pending resolution in a civil case involving the ownership of the same property. The civil case was filed by petitioners seeking a declaration of nullity of private respondent's title and the partition of the lot. The trial court denied the motion for suspension and proceeded with the arraignment of the petitioners. The petitioners entered a plea of not guilty to the charge. The issue in this case is whether the question of ownership in the civil case is a prejudicial question that justifies the suspension of the criminal case. The Supreme Court held that it is, as the resolution of the ownership issue in the civil case would determine the guilt or innocence of the petitioners in the criminal case. The court ordered the suspension of the criminal case until the ownership issue in the civil case has been resolved with finality.
ISSUES:
- Whether the question of ownership of Lot No. 3635-B, which is pending in another civil case, is a prejudicial question justifying the suspension of the proceedings in the criminal case against the petitioners.
RULING:
- Yes, the question of ownership of Lot No. 3635-B is a prejudicial question that justifies the suspension of the proceedings in the criminal case against the petitioners. The court held that a prejudicial question is a question that is based on a fact distinct and separate from the crime but so intimately connected with it that its resolution is determinative of the guilt or innocence of the accused. In this case, the resolution of the ownership issue would determine the guilt or innocence of the petitioners in the criminal case for squatting. The court further pointed out that the decision in the civil case nullifying the transfer certificate of title and declaring the lot as owned in common by the spouses and the petitioners would affect the criminal liability of the petitioners for squatting. Therefore, the court ordered the suspension of the proceedings in the criminal case until the question of ownership in the civil case has been resolved with finality, and thereafter proceed with the trial of the criminal case if the civil case is decided and terminated adversely against the petitioners. Otherwise, the court should dismiss the criminal case.