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JAMES WALTER P. CAPILI v. PEOPLE

FACTS:

The petitioner was charged with the crime of bigamy before the RTC of Pasig City. It was alleged that the petitioner contracted a second marriage with Shirley Tismo without legally dissolving his first marriage with Karla Medina-Capili. The petitioner filed a Motion to Suspend Proceedings, stating that there is a pending civil case for the declaration of nullity of the second marriage filed by Karla Medina-Capili and that the resolution of the civil case would exculpate him from the charge of bigamy. The arraignment and pre-trial were reset in view of the motion. Meanwhile, the RTC of Antipolo City rendered a decision declaring the second marriage void. The petitioner then filed a Manifestation and Motion to Dismiss, praying for the dismissal of the bigamy case on the ground that the second marriage had already been declared void. The RTC of Pasig City granted the motion and dismissed the case. The private respondent appealed the decision to the CA, which reversed the RTC's decision and remanded the case for further proceedings. Petitioner filed a Motion for Reconsideration, but it was denied. Hence, the present petition for review on certiorari before the Supreme Court.

ISSUES:

  1. Whether the pendency of the civil case for declaration of nullity of the second marriage serves as a prejudicial question in the instant criminal case.

  2. Whether the declaration of nullity of the second marriage in the civil case has any bearing on the criminal case for bigamy.

RULING:

  1. No. The Court held that a prejudicial question exists when the resolution of the issue raised in a civil action is indispensable or necessary for the resolution of the criminal action. In this case, the civil case for declaration of nullity of the second marriage is not intimately related or similar to the issue in the criminal case for bigamy. The resolution of the civil case would not determine whether or not the criminal action may proceed.

  2. No. The Court held that while the declaration of nullity of the second marriage in the civil case may have an effect on the civil aspect of the criminal case, it does not automatically extinguish the criminal liability for bigamy. The elements of bigamy are distinct from the elements of the civil case for nullity of marriage. The criminal case for bigamy must still proceed independently of the civil case.

PRINCIPLES:

  • A prejudicial question exists when the resolution of the issue raised in a civil action is indispensable or necessary for the resolution of the criminal action.

  • The declaration of nullity of a marriage in a civil case does not automatically extinguish the criminal liability for bigamy. The elements of bigamy are distinct from the elements of the civil case for nullity of marriage.