Case Digest (G.R. No. 221075) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 221075 decided on November 15, 2021 under the 1987 Constitution, Francis D. Malaki, Sr. and Jacqueline Mae A. Salanatin-Malaki (petitioners) challenged their convictions for bigamy under Article 349 of the Revised Penal Code. Francis first married Nerrian Maningo-Malaki on March 26, 1988 in Panabo City under Iglesia ni Cristo rites; they had two children. In early 2005, Francis abandoned his family and established a relationship with Jacqueline in Tagum City. On June 18, 2005, Francis and Jacqueline contracted a second marriage before a Municipal Trial Court judge, despite the subsistence of his first marriage. Francis and Jacqueline admitted to the subsequent marriage but claimed exculpation by virtue of their conversion to Islam and a Muslim solemnization allegedly held on June 5, 2005. They were charged by Information dated November 20, 2006 before the Regional Trial Court (RTC) of Tagum City, pleaded not guilty, and underwent trial. On May 7, 2012, the RTC found Case Digest (G.R. No. 221075) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Marriage and family background
- Francis D. Malaki and Nerrian Maningo-Malaki were married on March 26, 1988 under Iglesia ni Cristo; they had two children.
- In 2005, Francis moved to Tagum City, abandoned his family, and began cohabiting with Jacqueline Mae A. Salanatin.
- Subsequent marriage and charges
- On June 18, 2005, Francis and Jacqueline married in New Corella, Davao del Norte, before a Municipal Trial Court judge, despite Francis’s subsisting marriage.
- On November 20, 2006, they were charged with bigamy under Article 349 of the Revised Penal Code.
- Judicial proceedings
- The Regional Trial Court (May 7, 2012) convicted both of bigamy, ruling the Muslim Code inapplicable since Nerrian was non-Muslim.
- The Court of Appeals (April 24, 2015 decision; Sept. 17, 2015 resolution) affirmed that conviction.
- Petitioners filed a Rule 45 petition in the Supreme Court, claiming they converted to Islam and married under Muslim rites on June 5, 2005.
Issues:
- Are Francis and Jacqueline guilty of bigamy under Article 349 of the Revised Penal Code?
- Does conversion to Islam and subsequent marriage under the Muslim Code exculpate them from bigamy?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)