G.R. No. 224742 - De Guzman y Jumaquio vs. People

On April 8, 1994, Prudencio De Guzman and Arlene De Guzman were lawfully married before Branch 106 of the Regional Trial Court of Quezon City, with the ceremony solemnized by Judge Julieto P. Tabiolo.
Their marriage was substantiated by a certified Marriage Certificate issued by the Local Civil Registrar and a copy from the National Statistics Office (NSO), with the latter lacking the signature of the solemnizing officer—a discrepancy later explained as inadvertent.
Photos of the wedding ceremony and Prudencio’s own admissions further corroborated that the matrimonial union was validly celebrated.

In 2007, Prudencio allegedly abandoned his wife and children, setting the stage for later developments.
In December 2009, Arlene was informed by a friend that Prudencio had contracted a second marriage with Jean Basan at the Immaculate Church in Las Pinas City, a fact which she later confirmed on January 8, 2010, by personally verifying the marriage contract from the City Civil Registrar’s Office.
Following this discovery, Arlene filed a complaint before the Office of the City Prosecutor, accusing Prudencio of bigamy under Article 349 of the Revised Penal Code.

During the trial, Prudencio pleaded not guilty, contending that his marriage with Arlene was void due to an irregularity in the NSO-issued Marriage Certificate which lacked the signature of the solemnizing officer.
The trial court, however, downplayed this contention by noting the existence of a signed copy in the Local Civil Registry and relying on additional evidence such as wedding photos and Prudencio’s counter-affidavit, thereby confirming the validity of the marriage with Arlene.
The court further held that a person does not have the power to unilaterally declare a marriage void; only a judicial declaration of nullity could effect such a change, especially for the purpose of remarriage.

The trial court found all the elements of bigamy present, convicting Prudencio and imposing an indeterminate penalty ranging from a minimum of four years, two months, and one day of prision correccional to a maximum of six years and one day of prision mayor.
Prudencio appealed the conviction, during which Arlene executed an Affidavit of Desistance, remarking that she had reconciled with Prudencio and thus urging dismissal of the case.
The Court of Appeals, in its June 30, 2015 Decision, affirmed the trial court’s finding of bigamy, modified the penalty (extending the maximum imprisonment term to eight years and one day of prision mayor), and specifically ruled that the Affidavit of Desistance—executed 13 months after conviction—held no probative value in negating the established elements of the offense.
Prudencio subsequently filed a Motion for Reconsideration, arguing that the issuance of a Certificate of No Marriage Record by the NSO indicated no legal impediment to his remarriage; this motion was denied in the Court of Appeals’ April 21, 2016 Resolution.

Prudencio ultimately elevated the matter through a Verified Petition for Review on Certiorari, challenging whether the Court of Appeals erred in affirming his conviction for bigamy.
The Supreme Court denied the petition, underscoring that a judicial declaration of nullity is indispensable for a valid claim to remarry and that prudence and consistency in applying the Family Code preclude a unilateral declaration by an individual.

Whether Prudencio was entitled to unilaterally declare his marriage with Arlene void based on discrepancies in the Marriage Certificate;
Whether the absence of the solemnizing officer’s signature in the NSO-issued Marriage Certificate invalidated the marriage;
Whether Arlene’s Affidavit of Desistance, executed long after the trial court’s judgment, could negate the established elements of bigamy;
Whether the prosecution’s failure to produce the marriage license undermined the case against Prudencio;
Whether Prudencio’s reliance on the Certificate of No Marriage Record issued by the NSO provided a valid defense against the charge of bigamy.