GR 186597; (June, 2015) (Digest)
G.R. No. 186597, June 17, 2015
People of the Philippines, Petitioner, vs. Victoria R. Arambulo and Miguel Arambulo, Jr., Respondents.
FACTS
Respondents Victoria R. Arambulo and Miguel Arambulo, Jr. were charged with estafa before the Regional Trial Court (RTC) of Caloocan City for allegedly failing to remit rental collections to Anaped Estate Inc. (Anaped), a corporation formed to hold properties of the estate of Pedro Reyes. The complaint was filed by Jose Buban, Vice-President and General Manager of Anaped. Respondents filed a Motion to Suspend Proceedings on the ground of a prejudicial question due to two pending intra-corporate cases before other RTCs. SEC Case No. 03-99-6259 specifically questioned the authority of the Anaped Board of Directors and officers, including Buban, to act for the corporation. The trial court initially granted the suspension but later set it aside upon the prosecution’s motion for reconsideration. Respondents challenged this via certiorari before the Court of Appeals, which reinstated the suspension order, finding that a prejudicial question existed. The People of the Philippines then elevated the case to the Supreme Court.
ISSUE
Whether the Court of Appeals erred in declaring that a prejudicial question exists, warranting the suspension of the criminal proceedings for estafa.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The Court held that a prejudicial question exists in relation to SEC Case No. 03-99-6259. A prejudicial question requires that: (1) the previously instituted civil action involves facts intimately related to those in the criminal action; (2) the resolution of the issue in the civil action determines the guilt or innocence of the accused; and (3) jurisdiction is lodged in another tribunal. SEC Case No. 03-99-6259, which seeks to nullify the election of Anaped’s directors and officers including Buban, meets these requisites. The issue of Buban’s authority to act for Anaped is intimately related to the estafa case, as a valid demand from an authorized party is an element of estafa under Article 315(1)(b) of the Revised Penal Code. If respondents prevail in the SEC case and Buban’s authority is nullified, it would be as if no valid demand was made, thus determining their innocence in the criminal case. Therefore, the suspension of the criminal proceedings until the resolution of the intra-corporate case was proper.