G.R. No. 183805 - Capili vs. People

On June 28, 2004, petitioner was charged with bigamy before the RTC of Pasig City by Information alleging that on December 8, 1999, while still validly married to Karla Y. Medina-Capili, he contracted a second marriage with Shirley G. Tismo.
Petitioner moved to suspend criminal proceedings, invoking the pendency of a civil action for declaration of nullity of the second marriage filed by Karla Medina-Capili before the RTC of Antipolo City as a prejudicial question.

On December 1, 2004, the RTC of Antipolo City rendered a final decision declaring the second marriage void ab initio for being contracted during the subsistence of the first marriage.
Petitioner filed a Manifestation and Motion to Dismiss the bigamy case in RTC Pasig City. On July 7, 2006, the RTC granted the motion, holding that the second marriage had been judicially declared void and that “there is no more bigamy to speak of.”

Private respondent appealed to the Court of Appeals.
On February 1, 2008, the CA reversed and set aside the RTC’s dismissal order and remanded the case for further proceedings; its Resolution denying reconsideration was issued on July 24, 2008.
Petitioner then filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court, alleging that the CA disregarded binding jurisprudence and that the civil nullity ruling should bar the bigamy prosecution.

Whether the subsequent judicial declaration of nullity of the second marriage constitutes a valid ground for dismissing the criminal case for bigamy.