BELTRAN V.

PEOPLE

Facts: Beltran filed a petition for nullity of marriage against his wife consequently his wife then filed a criminal complaint for
concubinage against Beltran and the prosecutor finding probable cause to the information.

To forestall the issuance of warrant of arrest Beltran filed a motion to Defer and argued that the pendency of the civil case for the
declaration of nullity his marriage posed a prejudicial question. That there is a possibility that two conflicting decisions might result
from the civil case of annulment and criminal case of concubinage. In the civil case the trial court might declare the marriage as valid
by dismissing petitioner’s complaint but in the criminal case the trial court might acquit petitioner because the evidence shows that
his marriage is void on the ground of psychological incapacity.

RULING: Petitioner’s contention is untenable for a civil case to be prejudicial to a criminal action as to cause the suspension of the
latter pending the final determination of the civil case, it must appear not only that the civil case involves the same facts upon which
the criminal prosecution would be based, but also that in the resolution of the issue or issues raised in the aforesaid civil action, the
guilt or innocence of the accused would necessarily be determined.—herein petitioner need not present a final judgment declaring
his marriage void for he can adduce evidence in the criminal case of the nullity of his marriage other than proof of final judgment
declaring his marriage void.

Petitioners defense that he will be acquitted of the criminal case because his marriage is void from the beginning is not a defense.
For in the case of Landicho v. Relova Therefore he who contracts a second marriage before the judicial declaration of nullity of the
first marriage assumes the risk of being prosecuted for bigamy.

SESBRENO v. C.A.

Facts: VECO’s counsel commences a complaint against Sesbreno of theft for the tilted electric meter which causes an inaccurate
registration of electric consumption and the petitioner filed a case against VECO officials and employees who figured in the incident
for incriminating an innocent person under Art. 363.

MTC acquit VECO officials both for the criminal and civil charges. Petitioner then appealed the civil aspect to the RTC on which it
rendered in favor of Sesbreno and entitling him for civil damages. On motion for consideration RTC absolved Atty Loreto Durano
from civil liability. On the other hand private respondent Atty. Garcia and Nunez appealed for the reversal of RTC’S decision which is
denied.

Petitioner alleged that private respondent may still be held civilly liable because they were acquitted on the ground of reasonable
doubt.

ISSUE: Whether or not the respondent court erred in absolving private respondent from civil liability

RULING: Acquittal on the ground of reasonable doubt does not necessarily result to an award of civil liability to the offended party.
The civil liability has to be proved by preponderance of evidence either in the civil action contemplated by Article 29, or in the same
criminal action where the civil action is deemed impliedly instituted. 10 In this regard, settled is the rule that the judgment of
acquittal extinguishes the civil liability of the accused for damages only when it includes a declaration that the fact from which the
civil liability might arise did not
exist. 11 This is buttressed by Rule 111, Section 2(b) of the Rules of Court which states that "[e]xtinction of the penal action does not
carry with its extinction of the civil, unless the extinction proceeds from a declaration in a final judgment that the fact from which
the civil might arise did not exist".

YAP v. CABALES

Spouses Mirabueno have filed a civil action for collection of sum of money against Yap and subsequently for the same case a
criminal is filed against him for the violation of B.P. 22. Petitioner filed a separate motion to suspend proceedings on account of the
existence of prejudicial question, that the proceedings in the criminal cases be suspended until the civil case pending before RTC
were finally resolved.

The main contention of the petitioner is that a prejudicial question, as defined by law and jurisprudence, exists in the present case. It
is the petitioner's assertion that Civil Case Nos. 6231 and 6238 for collection of sum of money and damages were filed ahead of the
criminal cases for violation of B.P. Blg. 22. He further alleged that, in the pending civil cases, the issue as to whether private
respondents are entitled to collect from the petitioner despite the lack of consideration, is an issue that is a logical antecedent to the
criminal cases for violation of B.P. Blg. 22. For if the court rules that there is no valid consideration for the check's issuance, as
petitioner contends, then it necessarily follows that he could not also be held liable for violation of B.P. Blg. 22.

Petitioner further avers that B.P. Blg. 22 specifically requires, among other elements, that the check should have been issued for
account or for value. There must be a valid consideration; otherwise, no violation of the said law could be rightfully pursued. Petitioner
said that the reason for the dishonor of the checks was his order to the drawee bank to stop payment and to close his account in order
to avoid necessary penalty from the bank. He made this order due to the failure of Evelyn to deliver to him the titles to the purchased
properties to him.

On the other hand, the Office of the Solicitor General (OSG) contends that there is no prejudicial question in Civil Case Nos. 6231 and
6238 which would warrant the suspension of the proceedings in the criminal cases for violation of B.P. Blg. 22 against the petitioner.
The issue in the civil cases is not the validity of the sale between the petitioner and Evelyn, but whether the complainants therein are
entitled to damages arising from the checks. These checks were issued by the petitioner in favor of Evelyn, who, thereafter, negotiated
the same checks to private complainants. The checks were subsequently dishonored due to insufficiency of funds. The OSG maintains
that the resolution of such issue has absolutely no bearing on the issue of whether petitioner may be held liable for violation of B.P.
Blg. 22.[21]

RULING: The issue in the criminal cases is whether the petitioner is guilty of violating B.P. Blg. 22, while in the civil case, it is whether
the private respondents are entitled to collect from the petitioner the sum or the value of the checks that they have rediscounted
from Evelyn. The resolution of the issue raised in the civil action is not determinative of the guilt or innocence of the accused in the
criminal cases against him, and there is no necessity that the civil case be determined first before taking up the criminal cases. In the
aforementioned civil actions, even if petitioner is declared not liable for the payment of the value of the checks and damages, he
cannot be adjudged free from criminal liability for violation of B.P. Blg. 22. The mere issuance of worthless checks with knowledge of
the insufficiency of funds to support the checks is in itself an offense. [25]

Because the material question in the criminal case is whether petitioner had issued bad checks regardless of the purpose or condition
of issuance

Peoplev.Madali
16 January 2001Mendoza,
J.Facts:
•
An appeal from the decision of the RTC Branch 81 of Romblon, Romblon finding accused-appellantsguilty of the murder of Reynaldo M. Abrenica and sentencing
each of them to reclusion perpetua. Thebody of Reynaldo was found by his wife on the landing of the stairs of their house. An autopsy con-ducted by Dr.
Villaseñor of the PNP Crime Laboratory yielded to the conclusion that the cause of deathis intracranial hemorrhage as a result of traumatic head injury.
•
Three years after Reynaldo’s death, the case was filed after an alleged eyewitness, Mercy Villamor,surfaced and implicated the accused-appellants. Based on the
testimony of this witness, the accused-appellants were found guilty in the aforementioned decision.
•
The accused-appellants, in their appeal, alleged that the trial court erred in failing to resolve doubtsand discrepancies in its findings of fact in favor of the accused
and that the court erred in finding credi-ble the testimonies of Mercy Villamor and Dr. Villaseñor.
•
The complainant filed a Motion for Time to File Brief separate from that which the OSG would file, byway of an answer to the brief of accused-appellants. This
motion was denied. The OSG subsequentlyfiled a Manifestation recommending the acquittal of accused-appellants. In view of the position takenby the OSG,
complainant filed a Memorandum for the Private Complainant (after filing a Manifestationand Motion to File Brief) which was noted by the Court.
Ruling and Reasoning:
•

Rule 122, Sec.1 of the Revised Rules on Criminal Procedure provides that “any party may appeal from a judgment or final order, unless the accused will
be placed in double jeopardy.” It has been held that the word“party” in the provision includes not only the government and the accused but other
persons who may be af-fected by the judgment.
•
The complainant has an interest in the civil liability arising from the crime. Hence, in the prosecutionof the offense, the complainant’s role is that of a witness for
the prosecution.
•
Ordinarily, the appeal of the criminal cases involves as parties only the accused, as appellants, andthe State, represented by the SolGen, as the appellee. The
participation of the private offended partywould be a mere surplusage if the State were simply to seek affirmation of a judgment of conviction.However, where
the OSG takes a contrary position and recommends, as in this case, the acquittal of the accused, the complainant’s right to be heard as regards indemnity and
damages arises.
•
Nevertheless, the evidence is insufficient to sustain the accused-appellants’ conviction. Mercy Villamor’s testi-mony is riddled with inconsistencies, improbabilities
and uncertainties which relate to material points. Evidence,to be believed, must not only proceed from the mouth of a credible witness but must itself be credible.