G.R. No. 220916 , June 14, 2021
People of the Philippines, Petitioner, vs. Camilo Camenforte and Robert Lastrilla, Respondents.

FACTS

Spouses Aurora and Rafael Granda executed three Deeds of Sale on December 7, 1985, covering several parcels of land, in favor of the Uy siblings and respondent Robert Lastrilla. The deeds were annotated on the titles nearly 15 years later. After Aurora’s death, her grandson, Rafael A. Granda, filed a criminal complaint for falsification under Articles 171 and 172 of the Revised Penal Code against Silvina Granda (daughter), respondent Camilo Camenforte (notary public), Norma Lastrilla, Mary Uy-Cua, and the Uy siblings. He alleged the signatures of his grandparents were forged and the deeds were antedated, actually executed in 1999-2000. The Office of the City Prosecutor filed criminal Informations for falsification against Camenforte and Silvina Granda. After a petition for review, the Department of Justice initially dismissed the complaint against Lastrilla and the Uy siblings, but the Court of Appeals later found probable cause against Lastrilla, which the Supreme Court sustained in Lastrilla v. Granda. Consequently, criminal Informations were filed against respondents Camenforte and Lastrilla before the RTC. Meanwhile, two other children of the Granda spouses, Benjamin Granda and Blanquita Serafica, filed a civil case (Civil Case No. 2001-09-135) for nullification of titles and deeds against the Uy siblings, Silvina Granda, and respondent Lastrilla, alleging the deeds were falsified and void. The RTC dismissed this civil complaint on June 6, 2005, a decision which became final and executory after the CA dismissed the appeal. During the pendency of the criminal cases, respondents filed Motions to Dismiss on grounds of res judicata and the existence of a prejudicial question, citing the final judgment in the civil case. The RTC granted the motions and dismissed the criminal cases. The CA affirmed the dismissal, prompting the People, through the OSG, to file this Petition for Review.

ISSUE

Whether the final and executory decision in the civil case for nullification of the deeds of sale constitutes a prejudicial question that warrants the dismissal of the pending criminal cases for falsification.

RULING

No. The Supreme Court granted the petition, reversed the CA Decision and Resolution, and reinstated the criminal cases. The Court held that the doctrine of prejudicial question does not apply. A prejudicial question, under Rule 111, Section 7 of the Rules of Court, requires that: (a) the previously instituted civil action involves an issue similar or intimately related to the issue in the subsequent criminal action, and (b) the resolution of such issue determines whether or not the criminal action may proceed. The civil case for nullification, while involving the validity of the same deeds, was an action in personam between specific parties (the heirs who filed it and the defendants therein). Its final judgment, which upheld the deeds’ validity, binds only those parties and their privies. It does not constitute res judicata in the criminal cases, which are actions in rem prosecuted by the State against the accused for a public wrong. The State was not a party to the civil case, and the objective of criminal prosecution (punishment and correction) is distinct from the civil case’s objective (resolution of private rights). Therefore, the factual findings in the civil case are not conclusive upon the criminal court. The criminal court must independently evaluate the evidence to determine the accused’s guilt beyond reasonable doubt. The dismissal of the criminal cases based on the civil judgment was erroneous.