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MEYNARDO L. BELTRAN v. PEOPLE

FACTS:

The case involves a petition for review seeking to set aside an Order denying the issuance of a writ of preliminary injunction to stop the trial of a concubinage case. The petitioner, Meynardo Beltran, filed a petition for nullity of his marriage with his wife Charmaine Felix based on psychological incapacity. In response, Charmaine filed a criminal complaint for concubinage against Meynardo and his alleged paramour. Meynardo argued that the pending petition for nullity of marriage should suspend the criminal case because it poses a prejudicial question. The trial court denied Meynardo's motion to defer proceedings in the criminal case, leading him to file a petition for certiorari and a subsequent petition for review. The issue revolves around whether the pendency of the civil case for nullity of marriage constitutes a prejudicial question to the criminal case for concubinage. The Supreme Court held that the pendency of the civil case is not a prejudicial question to the criminal case and dismissed the petition for lack of merit.

ISSUES:

  1. Whether the pendency of the petition for declaration of nullity of marriage posed a prejudicial question to the determination of the criminal case for concubinage.

  2. Whether there was a possibility of conflicting decisions between the civil case for nullity of marriage and the criminal case for concubinage.

RULING:

  1. The pendency of the civil case for declaration of nullity of marriage did not pose a prejudicial question to the determination of the criminal case for concubinage. The resolution of the issue in the civil case did not necessarily determine the guilt or innocence of the accused in the criminal case.

  2. A final judgment declaring the marriage void is not necessary for the accused to adduce evidence of the nullity of his marriage in the criminal case. Even if the marriage is subsequently declared null and void, it does not serve as a defense to the charge of concubinage.

PRINCIPLES:

  • The principle of prejudicial question aims to avoid conflicting decisions and has two essential elements: (a) the civil action involves an issue similar or intimately related to the issue raised in the criminal action; and (b) the resolution of such issue determines whether or not the criminal action may proceed.

  • Article 40 of the Family Code provides that the absolute nullity of a previous marriage can only be invoked for purposes of remarriage based on a final judgment declaring the previous marriage void. However, for purposes other than remarriage, other evidence is acceptable to prove the nullity of the marriage.

  • Parties to a marriage cannot judge for themselves the nullity of their marriage, as it must be submitted to the judgment of the competent courts. Until the nullity of the marriage is declared, the presumption is that the marriage exists for all intents and purposes.