FACTS:

The case involves a petition for review seeking to set aside the decision of the Court of Appeals that reversed the order of the Regional Trial Court denying the respondent's motion for deferment of arraignment. In February 1997, the respondent and his mother represented to Plus Builders, Inc. (PBI) that they were the lawful owners of a lot in Imus, Cavite and that they acquired it from Juanito Tan Teng and Po Willie Yu. Relying on this representation, PBI purchased the lot. However, in April 1999, PBI discovered that the respondent and his mother did not have a valid title over the lot. PBI was also ousted from the possession of the lot by Tan Teng and Yu. Despite demands to return the money paid by PBI, the respondent and his mother refused to do so. As a result, PBI filed a complaint against them.

The respondent filed a motion to defer arraignment on the ground of a prejudicial question, i.e., the pendency of civil cases involving the same matter. The trial court denied the motion, prompting the respondent to file a petition for certiorari with the Court of Appeals. The Court of Appeals granted the petition and permanently enjoined the trial court from proceeding with the arraignment and trial of the criminal case. The Solicitor General filed the present petition seeking the reversal of the Court of Appeals decision. The issue to be resolved is whether the pendency of the civil cases is a prejudicial question warranting the suspension of the criminal proceedings.

ISSUES:

1. Whether or not the pendency of Civil Case Nos. SCA 1759 and 99-95381 is a prejudicial question justifying the suspension of the proceedings in the criminal case for estafa through falsification of public document filed against the respondent.

RULING:

1. The pendency of Civil Case Nos. SCA 1759 and 99-95381 is not a prejudicial question justifying the suspension of the proceedings in the criminal case for estafa through falsification of public document filed against the respondent.

PRINCIPLES:

• Prejudicial question - A prejudicial question is defined as that which arises in a case, the resolution of which is a logical antecedent of the issue involved therein, and the cognizance of which pertains to another tribunal. It is a question based on a fact distinct and separate from the crime but so intimately connected with it that it determines the guilt or innocence of the accused. The requisites for a civil action to be considered prejudicial to a criminal case are: (1) the civil case involves facts intimately related to those upon which the criminal prosecution would be based; and (2) in the resolution of the issue or issues raised in the civil action, the guilt or innocence of the accused would necessarily be determined.