Te v. Court of Appeals
REITERATIONFacts
The Antecedents: Arthur Te (petitioner) and Liliana Choa (private respondent) were married on September 14, 1988. They did not live together, and their child was born on April 21, 1989. Petitioner stopped visiting respondent thereafter. On May 20, 1990, while still married to respondent, petitioner contracted a second marriage with Julieta Santella. Respondent filed a complaint-affidavit in June 1990, leading to a bigamy information filed on August 9, 1990. Procedural History: Petitioner filed an annulment case on July 20, 1990, alleging concealment of pregnancy and psychological incapacity. Respondent filed an administrative case with the Professional Regulation Commission (PRC) on November 8, 1990, seeking revocation of petitioner's and Santella's engineering licenses due to immorality and falsification of marriage contract. Petitioner filed a demurrer to evidence and a motion to inhibit the RTC judge in the bigamy case. The RTC denied both the demurrer and the motion to inhibit. Petitioner filed two separate petitions for certiorari with the Court of Appeals (CA): one challenging the RTC judge's denial of the demurrer and motion to inhibit (CA-G.R. SP No. 23971), and another challenging the PRC Board's denial of his motion to suspend proceedings in the administrative case (CA-G.R. SP No. 26178). The CA consolidated these petitions and, in a decision dated August 31, 1994, upheld the RTC's denial of the motion to inhibit and the demurrer to evidence, and affirmed the PRC Board's denial of the motion to suspend proceedings. The CA ruled that no prejudicial question existed to warrant suspension. Petitioner's motion for reconsideration was denied by the CA on October 18, 1996. The Petition: Petitioner seeks reversal of the CA's decision, raising issues on the suspension of legal proceedings despite a pending annulment case, the denial of his demurrer to evidence, and the refusal to inhibit the trial judge.
Issue(s)
Whether the pendency of a civil case for annulment of marriage constitutes a prejudicial question that warrants the suspension of the criminal case for bigamy and the administrative case for revocation of license. Whether the trial court gravely abused its discretion in denying petitioner's demurrer to evidence. Whether the trial judge committed a serious legal error in not inhibiting himself from the criminal case.
Ruling
The petition is denied for lack of merit. The Court of Appeals did not err in upholding the denial of the motion to suspend proceedings, the demurrer to evidence, and the motion to inhibit.
Ratio Decidendi
On the issue of prejudicial question: The Court held that the pendency of the civil case for annulment of marriage did not pose a prejudicial question that would necessitate the suspension of the criminal case for bigamy. The Court emphasized that under Article 40 of the Family Code, the absolute nullity of a previous marriage cannot be invoked for remarriage unless there is a final judgment declaring it void. Therefore, at the time of the second marriage, the first marriage was legally subsisting, regardless of the subsequent annulment proceedings. The Court further clarified that a prejudicial question typically involves a civil and a criminal case, and not an administrative case and a civil case. Moreover, Section 32 of the PRC Rules and Regulations expressly prohibits the suspension of administrative proceedings before the Board due to pending civil or criminal cases involving the same facts, allowing the Board to proceed independently. The Court also noted that the administrative complaint included charges of immoral conduct beyond the bigamous marriage, further justifying the continuation of the proceedings. On the denial of the demurrer to evidence: The Court affirmed the appellate court's finding that the trial court did not commit grave abuse of discretion in denying the demurrer to evidence. The grant or denial of a demurrer is within the sound discretion of the trial court. The RTC found that the prosecution had established a prima facie case for bigamy, which is sufficient to deny a demurrer and require the accused to present evidence in his defense. The Court clarified that the denial of a demurrer based on a prima facie case is not an adjudication of guilt but merely an evaluation of the sufficiency of the prosecution's evidence to warrant a full-blown trial. The petitioner's proper recourse was to present his defense, not to appeal the denial of the demurrer at that stage. On the motion to inhibit: The Court agreed with the appellate court that the grounds raised by the petitioner against the trial judge did not conclusively show bias or prejudgment. The Court reiterated that mere suspicion of partiality is insufficient; clear and convincing evidence is required. The instances cited by the petitioner, such as the judge's remarks about dilatory motions and the requirement of a medical certificate for counsel's absence, did not deprive the petitioner of a fair and impartial trial. The Court noted that the judge's actions were within his sound discretion and aimed at ensuring the prompt disposition of the case, consistent with the duty to avoid unnecessary delays. The grounds for inhibition were not among those expressly mandated by Rule 137, Section 1 of the Rules of Court, making the decision to inhibit discretionary.
Main Doctrine
The pendency of a civil case for annulment of marriage does not pose a prejudicial question that necessitates the suspension of a criminal case for bigamy, especially when the Family Code requires a judicial declaration of nullity for remarriage. Furthermore, administrative proceedings before the PRC are not suspended by pending civil or criminal cases involving the same facts, as per their own rules.