View full case

ARTHUR TE v. CA

FACTS:

The case involves a petition for review on certiorari seeking to reverse the decision of the Court of Appeals. Petitioner Arthur Te and private respondent Liliana Choa were married in civil rites but did not live together after the marriage. Petitioner contracted a second marriage while his marriage with private respondent was still subsisting.

Private respondent filed a complaint for bigamy, while petitioner filed an action for annulment of his marriage to private respondent. Private respondent also filed an administrative case for the revocation of petitioner's engineering license.

The trial court denied petitioner's demurrer to evidence and motion to inhibit the trial judge. Petitioner filed a petition for certiorari with the Court of Appeals, which was consolidated with another petition for certiorari filed against the Board of Civil Engineering.

The Court of Appeals upheld the RTC's denial of the demurrer to evidence and motion to suspend proceedings. The court also ruled that there was no prejudicial question that would suspend the criminal case for bigamy. Petitioner filed a motion for reconsideration, which was denied.

Hence, the instant petition was filed raising several issues.

ISSUES:

  1. Whether the pendency of the civil case for annulment of petitioner's marriage poses a prejudicial question warranting the suspension of the criminal case for bigamy.

  2. Whether the filing of the civil case for annulment necessitates the suspension of the administrative proceedings before the PRC Board.

  3. Whether the trial court erred in denying petitioner's demurrer to evidence in the criminal case for bigamy.

  4. Whether or not the trial court erred in denying the demurrer to evidence and finding a prima facie case against the petitioner.

  5. Whether or not the trial judge exhibited partiality and bias against the petitioner, warranting his inhibition from the case.

RULING:

  1. The Court of Appeals ruled that the pendency of the civil case for annulment of marriage did not pose a prejudicial question warranting the suspension of the criminal case for bigamy. The outcome of the civil case had no bearing on the determination of the petitioner's innocence or guilt in the criminal case as the only requirement for the charge of bigamy is that the first marriage be subsisting at the time the second marriage is contracted.

  2. The Court held that the filing of the civil case for annulment did not necessitate the suspension of the administrative proceedings before the PRC Board as the concept of prejudicial question only applies to civil and criminal cases.

  3. The Court upheld the denial of petitioner's demurrer to evidence in the criminal case for bigamy. The trial court found that the prosecution had established a prima facie case for bigamy and petitioner's allegations in the demurrer were insufficient to justify its grant.

  4. The trial court did not err in denying the demurrer to evidence and finding a prima facie case against the petitioner. The order of the trial court denying the demurrer was not an adjudication on the merits but merely an evaluation of the sufficiency of the prosecution's evidence to determine whether or not a full-blown trial would be necessary to resolve the case. The trial court's observation that there was a prima facie case against the petitioner meant that the prosecution had presented sufficient evidence to sustain its proposition that petitioner had committed the offense of bigamy, and unless petitioner presents evidence to rebut the same, such would be the conclusion.

  5. The trial judge did not exhibit partiality and bias against the petitioner, warranting his inhibition from the case. The mere suspicion that a judge is partial is not enough to warrant his inhibition. There should be clear and convincing evidence to prove the charge of bias and partiality. Additionally, the grounds raised by the petitioner in his motion to inhibit were not among those expressly mentioned in the Revised Rules of Court. The decision to inhibit himself lay within the sound discretion of the trial judge, and in this case, there was no abuse of discretion.

PRINCIPLES:

  • The principle of suspending a criminal case in view of a prejudicial question is to avoid two conflicting decisions.

  • A civil case for annulment of marriage does not pose a prejudicial question in a criminal case for bigamy as the validity of the marriage is not determinative of the crime.

  • The filing of a civil case for annulment does not necessitate the suspension of administrative proceedings.

  • The grant or denial of a demurrer to evidence is within the sound discretion of the trial court and will only be disturbed in the presence of grave abuse of discretion.

  • A trial court's denial of a demurrer to evidence does not establish the guilt of the accused, but rather evaluates the sufficiency of the prosecution's evidence.

  • The test for determining the propriety of the denial of a motion to inhibit is whether the party was deprived a fair and impartial trial.

  • Mere suspicion of a judge's partiality is not enough to warrant his inhibition. Clear and convincing evidence of bias and partiality must be presented.

  • The decision to inhibit lies within the sound discretion of the judge and is not mandatory, except for cases where the judge, his spouse or child is pecuniarily interested or is related to either party within the sixth degree of consanguinity or affinity.