MEYNARDO BELTRAN v.

PEOPLE OF THE PHILIPPINES

G. R. No. 137567 June 20, 2000
Facts:

Meynardo L. Beltran and Charmaine E. Felix were married on 16 June 1973 according to
the Roman Catholic rites in Quezon City. After living together for twenty-four years blessed with
4 children, Beltran on 7 February 1997 filed a petition with the Regional Trial Court for nullity of
marriage on the ground of psychological incapacity under Article 26 of the Family Code.
Charmaine E. Felix in her Answer to the Petition alleged that it was Beltran who
abandoned the conjugal home and lived with a woman named Milagros Salting. Charmaine then
filed a criminal action before the City Prosecutors Office of Makati for concubinage under Article
334 of the Revised Penal Code against her husband, Meynardo L. Beltran and Milagros Salting.
Eventually a criminal case for concubinage against Beltran and Salting was filed before the
Metropolitan Trial Court of Makati.
Beltran filed a motion to suspend the criminal action for concubinage while the case for
nullity of marriage is pending resolution. He argued that there is a possibility that two
conflicting decisions might result from the civil case for nullity of the marriage and the criminal
action for concubinage. It is possible that the RTC might declare the marriage valid by
dismissing his Complaint but in the criminal action, the Metropolitan Trial Court may acquit him
because the evidence shows that his marriage is void on the ground of psychological incapacity.
Issue:

Whether or not the pending civil action for declaration of nullity of marriage based on
psychological incapacity under Article 26 of the Family Code constitute a prejudicial question in
the criminal action for concubinage filed by Charmaine E. Felix against Meynardo L. Beltran and
Milagros Salting?
Ruling:
No. The reason for the principle of prejudicial question is to avoid two conflicting
decisions. There are two essential elements of the existence of a prejudicial question: (1) the
civil action involves an issue similar or intimately related to the issue raised in the criminal
action; and (2) the resolution of such issue determines whether or not the criminal action may
proceed.
The basic issue in the civil action for declaration of nullity of marriage is not a prejudicial
question to the criminal action for concubinage. For the civil action to be considered prejudicial
to the criminal action as to cause the suspension of the latter, it must appear that the former
involves the same facts upon which the latter would be based and that in the resolution of the
issue or issues raised in the civil action, the guilt or innocence of the accused be determined.
The judgment that might be rendered in the civil action declaring the marriage void is not
necessary to be presented in the criminal action because the accused may present evidence
other than the judgment in the civil action.
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