Prejudicial question

"xxx.

In sum, the prejudicial factual finding of genuineness of Sps. Granda's signatures on the questioned Deeds of Sale in Civil Case No. 2001-09-135 must operate to bar the prosecution of respondents for the falsification of the same signatures on the same questioned Deeds of Sale. This is the heart of the doctrine of a prejudicial question, without the appreciation of which the application of said doctrine may never come to be.

Finally, petitioner's submission that it must be allowed to present new evidence in order to establish the allegation of forgery which was already conclusively found as without basis in Civil Case No. 2001-09-135, is to completely render nugatory the very premise of a prejudicial question, for one, and the value of finality of judgments, for another.

Chiefly, the doctrine of a prejudicial question serves the following purposes: (i) to avoid multiplicity of suits; (ii) avoid unnecessary litigation; (iii) avoid conflicting decisions; (iv) safeguard the rights of the accused; and (v) unclog the courts' dockets.115 Therefore, if petitioner is allowed to effectively relitigate a point of prejudicial fact already tried and found by another court in a civil case, and which has, in this case, already attained finality, then the above purposes of the doctrine of a prejudicial question will be wholly defeated.

To be sure, the Court is not unmindful of the fact that there may have been failures on the discharge of proof of the plaintiffs in Civil Case No. 2001-09-135. However, the Court cannot turn away from the pivotal fact that the said civil case already held as unfounded the very same allegation of forgery that the pending criminal cases seek to prove. What's more, said factual finding in the Civil Case No. 2001-09-135 had already obtained finality, when the decision of the RTC therein became final with the CA's Resolution dated October 26, 2007 in CA-G.R. CV No. 00990.

Unfortunately for petitioner's cause, therefore, the Court finds no outweighing benefit in overturning the finality of RTC-Branch 9's decision in Civil Case No. 2001-09-135, the core finding of which predisposes the Court now to dismiss the pending criminal cases.

WHEREFORE, the Petition is hereby DENIED. Accordingly, the Decision dated April 27, 2015 and Resolution dated September 23, 2015 of the Court of Appeals Former Eighteenth Division in CA-G.R. CEB-CR No. 01796 are hereby AFFIRMED with MODIFICATION, in that the Resolution of the Regional Trial Court of Tacloban City in Criminal Case Nos. 2008-03-109 to 111 against respondent Robert Lastrilla, and Criminal Case Nos. 2001-07-482 to 484 against respondent Camilo Camenforte are AFFIRMED by virtue of the existence of a prejudicial question.chanroblesvirtualawlibrary

SO ORDERED.

Xxx. "


G.R. No. 220916, June 14, 2021

PEOPLE OF THE PHILIPPINES, Petitioner, v. CAMILO CAMENFORTE AND ROBERT LASTRILLA, Respondents.


https://www.chanrobles.com/cralaw/2021junedecisions.php?id=757