Digest: Beltran v. People (G.R. No.

137567, June 20, 2000)

Facts:
Meynardo Beltran filed a petition for nullity of marriage on the ground of psychological
incapacity. While this civil case was pending, his wife filed a criminal complaint for concubinage
against him. Beltran sought to suspend the criminal case, arguing that the outcome of the civil
case would affect the criminal proceedings.

Issue:
Whether the pending civil case for nullity of marriage constitutes a prejudicial question to the
criminal case for concubinage.

Ruling:
The Supreme Court held that the civil case for nullity of marriage is not a prejudicial question to
the criminal case for concubinage. The marriage is presumed valid until declared void by final
judgment, and the criminal case may proceed independently of the civil case.
People v. Camenforte, G.R. No. 220916 (14 June 2021)
Doctrine:
A final and executory civil judgment on the genuineness of signatures in a questioned document
bars subsequent criminal prosecution for forgery involving the same documents, as the issues
are intimately intertwined and conclusively settled in the civil case.

Facts:
Spouses Granda sold several parcels of land through three Deeds of Sale, which their children
later claimed were forged. The civil court found the signatures on the Deeds of Sale to be
genuine, dismissing the forgery claim. Criminal cases for falsification were then filed against the
alleged forgers, including the notary public.

Issue:
Whether the criminal prosecution for forgery can proceed after a civil court has conclusively
found the signatures to be genuine.

Ruling:
The Supreme Court held that the civil court’s final finding of genuineness of the signatures
precludes further criminal prosecution for forgery, as the issues are identical and already
resolved. Allowing the criminal case to proceed would be wasteful and contrary to the principle
of conclusiveness of judgment.
Digest: Honasan II v. DOJ Panel (G.R. No. 159747, April 13, 2004)
Doctrine:
The Ombudsman and the Department of Justice (DOJ) have concurrent jurisdiction to conduct
preliminary investigations of offenses committed by public officers; the Ombudsman has primary
jurisdiction, but the DOJ is also authorized to investigate under the law.
Honasan II v. DOJ Panel, G.R. No. 159747 (2004)

Facts:
Senator Gregorio Honasan was implicated in the 2003 Oakwood mutiny and charged with coup
d’etat. The DOJ conducted a preliminary investigation based on affidavits and evidence linking
Honasan to the planning and execution of the coup. Honasan challenged the DOJ’s jurisdiction,
arguing that only the Ombudsman could investigate public officials like him.
Honasan II v. DOJ Panel, G.R. No. 159747 (2004)

Issue:
Whether the DOJ has jurisdiction to conduct a preliminary investigation over a public officer
charged with coup d’etat.
Honasan II v. DOJ Panel, G.R. No. 159747 (2004)

Ruling:
The Supreme Court held that the DOJ and the Ombudsman have concurrent jurisdiction to
conduct preliminary investigations of public officers. The petition was dismissed for lack of merit,
affirming the DOJ’s authority to proceed.
Digest: Luz v. People (G.R. No. 197788, February 29, 2012)
Doctrine:
A person temporarily detained for a traffic violation is not considered "under arrest" unless there
is clear intent by the police to deprive him of liberty; thus, evidence obtained from an illegal
arrest is inadmissible in court Luz v. People, G.R. No. 197788 (2012).

Facts:
Rodel Luz was flagged down by police for a traffic violation and brought to a police sub-station.
While waiting for a traffic citation ticket, police searched him and found shabu in his possession.
He was charged and convicted of illegal possession of dangerous drugs.

Issue:
Whether the warrantless search and subsequent arrest of Luz for a traffic violation were valid.

Ruling:
The Supreme Court held that Luz was not lawfully arrested, as there was no intent to take him
into custody for the traffic violation, which was punishable by fine only. Consequently, the search
was illegal and the evidence obtained was inadmissible, leading to Luz's acquittal
Go v. Court of Appeals (G.R. No. 101837, February 11, 1992)
Doctrine:
An accused is entitled to a preliminary investigation before being charged in court, and the
absence thereof is a violation of due process.

Facts:
Rolito Go was accused of murdering Eldon Maguan after a traffic altercation. He was arrested
without a warrant and charged with murder without the benefit of a preliminary investigation. Go
filed motions for immediate release and for a proper preliminary investigation, which were
initially granted but later revoked by the trial court.

Issue:
Whether Go was deprived of his right to a preliminary investigation before being charged in
court.

Ruling:
The Supreme Court held that Go was not lawfully arrested without a warrant and was entitled to
a preliminary investigation. The trial on the merits was ordered suspended until the conclusion
of the preliminary investigation, and Go was allowed to post bail for his provisional liberty.
People v. Andan (G.R. No. 116437, March 6, 1997)
Doctrine:
A confession made voluntarily, even in the absence of counsel but not during custodial
investigation, may be admitted as evidence if made spontaneously and in the presence of
disinterested witnesses.

Facts:
Pablito Andan was convicted of the special complex crime of rape with homicide after
confessing to the crime before the mayor, police, and media. The victim was found dead with
evidence of rape and traumatic injuries, and Andan’s confession was corroborated by physical
and circumstantial evidence. Andan initially denied involvement but later admitted guilt and
reenacted the crime in the presence of witnesses.

Issue:
Whether Andan’s confession and the evidence presented were sufficient to sustain his
conviction for rape with homicide.

Ruling:
The Supreme Court held that Andan’s confession, made voluntarily and corroborated by
evidence, was admissible and sufficient for conviction. The Court affirmed the conviction and
imposed the penalty of death, with the records to be forwarded to the Office of the President for
possible exercise of executive clemency.
People v. Malngan, G.R. No. 170470 (September 26, 2006)
Doctrine:
Conviction for arson may be based on circumstantial evidence if the circumstances, when taken
together, lead to no other logical conclusion but the guilt of the accused beyond reasonable
doubt.

Facts:
Edna Malngan, a housemaid, was seen hurriedly leaving her employer’s house early in the
morning. Shortly after, a fire broke out, gutting the house and causing multiple deaths.
Witnesses identified Malngan as the person who left the scene, and she later confessed to
setting the fire due to unpaid wages.

Issue:
Whether the circumstantial evidence presented was sufficient to convict Malngan of arson with
multiple homicide.

Ruling:
The Supreme Court held that the circumstantial evidence, including eyewitness accounts and
Malngan’s confession, was sufficient to establish her guilt beyond reasonable doubt. Her
conviction for arson with multiple homicide was affirmed.
People v. Judge Ayson, G.R. No. 85215 (July 7, 1989)
Doctrine:
The right against self-incrimination gives a person the option to refuse to answer incriminating
questions, but an accused in a criminal case cannot be compelled to testify at all, and their
refusal to do so cannot be used against them. People of the Philippines v. Ayson, G.R. No.
85215 (1989)

Facts:
An employee of Philippine Airlines was investigated for irregularities in ticket sales. During the
investigation, the employee made written statements admitting misuse of proceeds, without the
assistance of counsel. The trial court excluded these statements as evidence, ruling they were
taken without informing the accused of his constitutional rights and without counsel present.

Issue:
Whether the statements made by the accused during the investigation, without counsel, are
admissible in evidence.

Ruling:
The Supreme Court held that the right against self-incrimination allows a witness to refuse to
answer incriminating questions, but an accused in a criminal case cannot be compelled to testify
at all. Statements obtained without informing the accused of his rights and without counsel are
inadmissible in evidence.
Rosete v. Lim (G.R. No. 136051, June 8, 2006)
Doctrine:
The right against self-incrimination allows an accused in a criminal case to refuse to take the
witness stand altogether, but a party in a civil case may only invoke the privilege as each
incriminating question is asked.

Facts:
Juliano and Lilia Lim filed a civil case for annulment and specific performance with damages
against Rosete, Mapalo, and others. The trial court allowed the taking of depositions of Mapalo
and Rosete, who objected, citing pending criminal cases for B.P. 22 and estafa. They argued
that being compelled to testify in the civil case would violate their right against self-incrimination
due to the similarity of issues in the civil and criminal cases.

Issue:
Whether the trial court erred in allowing the taking of petitioners’ depositions in the civil case
despite their claim of the right against self-incrimination.

Ruling:
The Supreme Court held that as parties in a civil case, petitioners could not refuse to take the
witness stand entirely but may invoke the right against self-incrimination only as to specific
questions. The petition was dismissed for lack of merit, affirming the trial court’s orders allowing
the depositions to proceed.