Facts:

This case involves consolidated petitions for review on certiorari under Rule 45 of the 1997 Revised Rules of Civil Procedure, stemming from a complaint-affidavit filed by Sally Go-Bangayan (respondent) against Benjamin B. Bangayan, Jr. and Resally de Asis Delfin (petitioners). The events began when Benjamin Jr. married Sally Go in Pasig City on March 7, 1982, with whom he had two children. However, it was later revealed that Benjamin Jr. also married Azucena Alegre in Caloocan City on September 10, 1973, and subsequently took Resally as a concubine and married her on January 5, 2001, under the alias "Benjamin Z. Sojayco." The City Prosecutor of Caloocan conducted a preliminary investigation and issued a Resolution on June 5, 2002, recommending the filing of an information for bigamy against both petitioners, which was filed on November 15, 2002, at the Regional Trial Court (RTC) of Caloocan City, Branch 126, referred to as Criminal Case No. C-66783.

After both petiti

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Facts:

Parties and Allegations

• Sally Go-Bangayan – the respondent and private offended party who filed a complaint-affidavit accusing the petitioners of bigamy.
• Benjamin B. Bangayan, Jr. – accused of bigamy; married to Sally Go and later entered into additional marital relationships.
• Resally de Asis Delfin – likewise accused of bigamy; involved in a marital relationship with Benjamin, Jr. under the false name “Benjamin Z. Sojayco.”

Marital Chronology and Bigamous Acts

• Marriage to Sally Go
• On March 7, 1982, Benjamin, Jr. married Sally Go in Pasig City.
• The couple had two children during the course of their marriage.
• Marriage to Resally
• Benjamin, Jr. later took Resally as his concubine and eventually married her on January 5, 2001.
• He used the fictitious name “Benjamin Z. Sojayco” for the marriage to Resally.
• With Resally, Benjamin, Jr. fathered two children.
• Prior Marriage to Azucena Alegre
• Evidence revealed that Benjamin, Jr. had contracted a marriage with Azucena Alegre on September 10, 1973 in Caloocan City.
• This prior marriage raises questions regarding the validity of his subsequent marital relationships.

Procedural History

• Criminal Prosecution Initiation
• Following the complaint, a preliminary investigation was conducted by the Caloocan City Prosecutor.
• A Resolution dated June 5, 2002, recommended the filing of an information for bigamy against Benjamin, Jr. and Resally.
• The information was filed on November 15, 2002, and raffled to the Regional Trial Court (RTC) of Caloocan City, Branch 126, in Criminal Case No. C-66783.
• Trial Court Proceedings
• After arraignment where both petitioners pleaded not guilty, the prosecution completed the presentation of its evidence.
• On September 8, 2003, both petitioners filed motions for leave to file a demurrer to evidence.
• The RTC granted the motions on September 29, 2003.
• On October 20, 2003, Benjamin, Jr. formally filed his Demurrer to Evidence, arguing two key points:
• His marriage to Sally Go was legally invalid due to the prior marriage to Azucena.

ii. The prosecution failed to demonstrate that “Benjamin Z. Sojayco Jr.” and himself were the same person.

Nature of the Consolidated Petitions

• Petitioners (Benjamin, Jr. and Resally) challenged the CA’s intervention and reversal of the RTC’s dismissal on the grounds of:
• Violation of the right against double jeopardy.
• Alleged grave abuse of discretion amounting to lack or excess of jurisdiction.
• Sally Go, as the respondent and private offended party, asserted her standing to question the RTC decision, asserting that her due process rights were infringed given the dismissal of the criminal proceedings against the accused.

Issue:

Issues Raised by Benjamin, Jr.

• Whether the Court of Appeals, in a petition for certiorari proceedings, may review factual matters presented by the parties in the lower court without violating the accused’s constitutional right against double jeopardy (Section 21, Article III, 1987 Constitution).
• Whether the RTC’s order granting the Demurrer to Evidence was issued with grave abuse of discretion that constitutes either lack of jurisdiction or excess of jurisdiction, thereby warranting the CA’s intervention.
• Whether the prosecution was denied due process by allegedly overlooking key pieces of evidence during trial.

Issues Raised by Resally

• Whether the CA erred in accepting Sally Go’s petition for certiorari given that, as a private offended party, she allegedly lacked legal standing to question a criminal proceeding without the consent or intervention of the Office of the Solicitor General (OSG) or the City Prosecutor’s Office of Caloocan.
• Whether the CA’s decision to order further proceedings violated the petitioners’ right against double jeopardy by re-prosecuting them for an offense for which a dismissal (or acquittal) had already been rendered.

Consolidated Issue for Determination

• Whether Sally Go possessed the legal standing to file a petition for certiorari challenging the RTC’s dismissal of the criminal case.
• Whether the reversal of the RTC’s dismissal by the CA, thereby ordering the remand for further trial, violated the petitioners' constitutional right against double jeopardy.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)