Note: To be written
G.R. No. 220916, June 14, 2021
PEOPLE OF THE PHILIPPINES, Petitioner, v. CAMILO CAMENFORTE AND ROBERT
LASTRILLA, Respondents.
FACTS:
The present controversy involves the sale of several parcels of land owned by Aurora Granda
(Aurora) in her lifetime.
Five months after Aurora's death, Rafael, the grandson and a legal heir of Sps. Granda, filed a
complaint for violation of Articles 171 and 172 of the Revised Penal Code against Silvina,
respondent Camenforte, Norma Lastrilla, and the Uy siblings. Rafael claimed that the signatures of
his grandparents appearing in the three Deeds of Sale were falsified.
In their counter-affidavit, the Uy siblings submitted that they validly bought the subject
properties.
Silvina and respondent Camenforte were charged with Falsification under Article 171 sub-
paragraphs 1, 2 and 5 of the Revised Penal Code in three Information before the RTC-Branch 8 of
Tacloban City.
While the criminal cases were pending, Benjamin R. Granda (Benjamin) and Blanquita R. Serafica
(Blanquita), children of Sps. Granda, filed a Complaint for Nullification of Title and Deeds with
Damages (Civil Case) against the Uy siblings, Silvina and respondent Lastrilla before the RTC-
Branch 9 of Tacloban City. Benjamin and Blanquita alleged that the subject Deeds were falsified
and were null and void.
The RTC dismissed the complaint in Civil Case. Benjamin and Blanquita interposed an appeal
before the CA which dismissed the same.
Through Motions to Dismiss, both respondents prayed that the criminal cases against them be
dismissed on the grounds of res judicata and the existence of a prejudicial question. These
Motions were granted.
Petitioner filed a Motion for Reconsideration of the said dismissal, but the same was dismissed.
Petitioner thereafter appealed to the CA which affirmed the trial court’s decision. Hence this
petition.
Issues
Whether Criminal Case Nos. 2008-03-109 to 111 and 2001-07-482 to 484 should be dismissed on
the ground of a prejudicial question (under the Civil Case).
RULING:
Prejudicial question is understood in law to be that which must precede the criminal action, that
which requires a decision before a final judgment is rendered in the principal action with which
said question is closely connected.
The elements of a prejudicial question are that (a) the previously instituted civil action involves an
issue similar or intimately related to the issue raised in a subsequent criminal action, and (b) the
resolution of such issue determines whether or not the criminal action may proceed. The rule
is directory insofar as the strict sequence of the cases is involved, but is mandatory as
to the requirement that the issue in the civil case must be so similar or intimately
related to the issue in the criminal case, so as to determine whether or not the criminal
action may proceed.
With the existence of a prejudicial question appreciated in these cases, the next inevitable query
is whether the court's finding of genuineness of Sps. Granda's signatures on the Deeds of Sale in
Note: To be written
Civil Case No. 2001-09-135 is determinative of the alleged guilt of respondents in the instant
criminal actions.
The Court answered in the affirmative.
As correctly expounded on by the CA, on the matter of identity of issues:
The genuineness of the deeds of sale, which is the subject of the civil case, is apparently
determinative of the outcome of the forgery case with respect to the same deeds of sale. Notably,
when the subject deeds of sale were found to be genuine, then it necessarily follows that there
was no forgery committed on these documents. The pronouncement of validity of the deeds of
sale in the civil case is conclusive upon the criminal case preventing the court a quo from re-
litigating the same issue and then ending up with a contrary ruling.
