G.R. No. 126746 ; November 29, 2000
Arthur Te, petitioner, vs. Court of Appeals, and Liliana Choa, respondents.

FACTS

Petitioner Arthur Te and private respondent Liliana Choa were married in 1988. While this marriage was subsisting, petitioner contracted a second marriage with Julieta Santella in 1990. Based on a complaint by Choa, an information for bigamy was filed against Te. Concurrently, Te filed a civil action for the annulment of his first marriage, alleging he was forced into it and that Choa was psychologically incapacitated. Separately, Choa initiated an administrative case before the Professional Regulation Commission (PRC) seeking the revocation of Te’s engineering license for immorality and falsification.
In the criminal case, after the prosecution rested, Te filed a demurrer to evidence, which the Regional Trial Court (RTC) denied, finding a prima facie case. Te also filed a motion to inhibit the trial judge, alleging antagonism, which was likewise denied. He then filed a petition for certiorari with the Court of Appeals (CA) challenging these denials. Simultaneously, Te moved to suspend the PRC administrative proceedings pending the resolution of the civil annulment and criminal cases, arguing a prejudicial question. The PRC Board denied this motion, prompting Te to file another certiorari petition with the CA. The appellate court consolidated these petitions.

ISSUE

The primary issues were: (1) whether the criminal and administrative proceedings should be suspended pending the civil annulment case; (2) whether the trial court gravely abused its discretion in denying the demurrer to evidence; and (3) whether the trial judge should have inhibited himself.

RULING

The Supreme Court denied the petition, affirming the Court of Appeals. On the first issue, the Court held that no prejudicial question existed to warrant suspension. A prejudicial question arises only when a civil action involves an issue similar or intimately related to an issue in a criminal case, and its resolution determines whether the criminal action may proceed. The civil case for annulment does not pose a prejudicial question to the bigamy case. For bigamy, the prosecution must only prove the existence of the first and second marriages. The validity of the first marriage is presumed, and any alleged defect, such as vitiation of consent, is a matter of defense to be raised in the criminal case itself, not a prejudicial question requiring prior civil resolution. Furthermore, the administrative case before the PRC is independent and can proceed separately, as it involves the professional conduct of the petitioner, not the precise elements of the criminal charge.
Regarding the demurrer to evidence, the Court found no grave abuse of discretion in its denial. A demurrer challenges the sufficiency of the prosecution’s evidence. The RTC correctly ruled that the prosecution had established a prima facie case by presenting evidence of both marriages, which are the core elements of bigamy. The grant or denial of a demurrer rests on the trial court’s sound discretion. Finally, on the motion for inhibition, the Court upheld the CA’s finding that petitioner failed to present concrete evidence of the judge’s partiality or prejudgment. Bare allegations of antagonism are insufficient to prove bias warranting inhibition. The judge’s actions were within the bounds of judicial discretion to control the proceedings and prevent delay.