People v. Camenforte

Summary

The Supreme Court dismissed criminal charges for falsification against a notary public and co-accused, affirming lower court rulings based on the doctrine of prejudicial question. While the Granda heirs alleged that signatures on 1985 deeds of sale were forged, a prior civil case conclusively found the signatures genuine after full trial. Although res judicata did not technically apply due to different parties between civil and criminal cases, the Court held that the prejudicial question doctrine barred further prosecution. The final judicial determination of signature genuineness in the civil case necessarily resolved all falsification charges, including forging signatures, false acknowledgment before a notary, and antedating documents. The decision emphasizes the analogous application of prejudicial question doctrine to prevent multiplicity of suits and conflicting judgments, even when technical procedural requirements are not strictly met.