Benitez v. Concepcion

Summary

Supreme Court denied petition for prohibition seeking to stop City Fiscal from proceeding with criminal falsification investigation. Petitioners argued that pending civil annulment case involving same mortgage documents created prejudicial question requiring suspension of criminal proceedings. Court ruled no prejudicial question existed since both cases involved identical forgery issues. Applied doctrine that prejudicial questions must involve facts distinct from but intimately connected to the crime that determine guilt or innocence. Since civil annulment and criminal falsification cases addressed same forgery allegations, no preliminary civil determination was required. Court reaffirmed general rule that criminal cases take precedence over civil cases, dissolving injunction and allowing criminal investigation to proceed.