Italian Prime Minister Silvio Berlusconi was absent from the courtroom when his bribery trial re-opened in Milan Monday supposedly because he was busy with an emergency cabinet meeting on the crisis in Libya.

This prompted critics to call the scenario a increasingly frequent legal strategy over the coming weeks and months.

The premier is in the midst of trials on a wide array of charges, ranging from bribery and tax evasion to abuse of power and paying a minor for sex.

Berlusconi has been named in at least 17 lawsuits since he first came into the political scene in 1994, but he has so far managed to escape prosecution.

But in January, a key part of Berlusconi's defense was removed when Italy's Constitutional Court stripped away the essential planks of a controversial immunity law that protected Berlusconi from prosecution while in office.

Since then, three trials have restarted and judges say they will not be shy in calling Berlusconi to answer charges before them.

With military attacks underway in Libya, unrest across North Africa, and the impacts of the March 11 earthquake and tsunami in Japan still being felt, critics say Berlusconi could start using closed-door government meetings to delay hearings or avoid appearing in court.

"I think it's clear that Berlusconi would do anything to avoid prosecution, and he has the power to set these emergency meetings whenever he wants," Paolo Renato, a former Italian lawmaker and harsh Berlusconi critic, said in an interview. "I think anyone can draw a conclusion from that."

Opposition newspapers agreed, with several running online commentary critical of Berlusconi's decision to skip the trial because of the hastily called cabinet meeting.

After the meeting Monday, Berlusconi declared that Italian fighter planes patrolling the air above Libya "have not and will not shoot" at Libyan fighters.

Though Italy is a leading participant in the coalition attacking Libya, the two countries are former allies that until February had a "friendship treaty" that prohibited military action against the other.

Berlusconi also asked that the military operations be put under the command of the North Atlantic Treaty Organization, or NATO, rather than any single country.

Meanwhile, the Milan trial where Berlusconi was scheduled to appear went ahead without him. In that case, Berlusconi is accused of paying British attorney David Mills 600,000 U.S. dollars to commit perjury in two corruption trials in the 1990s.

In 2008, Mills was found guilty of accepting bribe from Berlusconi but Berlusconi was never tried for it.

Mills' conviction and 54-month jail sentence were overturned a year ago, however, on technical grounds. Both Berlusconi and Mills have denied any wrongdoing.

Earlier this year, Berlusconi's lawyers said the prime minister could not attend the hearings because his schedule was too busy.

But earlier in March, the attorneys and the Milan judges reached a compromise: hearings would take place only on Mondays from March to the end of July -- the dates Berlusconi's lawyers said would allow the prime minister to appear in person.

Monday's hearing was the first since the compromise was reached.