Case Digest (G.R. No. 165842) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Eduardo P. Manuel, the petitioner, Eduardo Manuel, was first married to Rubylus GaAa on July 28, 1975 before Msgr. Feliciano Santos in Makati. In January 1996, he met 21-year-old Tina B. Gandalera in Dagupan City. Claiming to be single, he wooed her, obtained her parents’ consent, and solemnized a second marriage on April 22, 1996 before Judge Antonio C. Reyes of the Regional Trial Court of Baguio City, Branch 61. Manuel and Gandalera lived together for about three years, built a home in Baguio, and initially enjoyed marital harmony. Beginning in 1999, Manuel physically abused and financially neglected Gandalera, finally abandoning her in January 2001. In August 2001, through the National Statistics Office, Gandalera discovered her husband’s prior marriage. She filed a complaint for bigamy. On July 2, 2002, the RTC of Baguio City, Branch 3 convicted Manuel of bigamy under Article 349 of the Revised Penal Code and sentenced him to an indeterminate Case Digest (G.R. No. 165842) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Matrimonial History and Charge
- On July 28, 1975, Eduardo P. Manuel married Rubylus GaAa before Msgr. Feliciano Santos in Makati (then Rizal province).
- On April 22, 1996, he contracted a second civil marriage with Tina B. Gandalera in Baguio City, declaring himself “single.”
- Relationship, Breakdown and Discovery
- Eduardo met Tina in January 1996 in Dagupan City, courted her in Baguio City, and convinced her of his singleness.
- The couple built a home and lived together until 1999, when Eduardo grew distant and, in January 2001, abandoned Tina and ceased support.
- In August 2001 Tina obtained an NSO‐certified copy of Eduardo’s 1975 marriage contract, learning of his prior marriage.
- Proceedings Below
- The Regional Trial Court (RTC) of Baguio City, Branch 3, found Eduardo guilty of bigamy on July 2, 2002, sentencing him to 6 years 10 months to 10 years’ imprisonment and awarding Tina ₱200,000 moral damages.
- On June 18, 2004, the Court of Appeals (CA) affirmed the conviction, modified the penalty to 2 years 4 months 1 day to 10 years, and upheld the moral damages award.
- Eduardo filed a petition for review on certiorari before the Supreme Court, challenging the need for judicial declaration of presumptive death and the moral damages award.
Issues:
- Presumptive Death Requirement
- Whether the absent first spouse must be judicially declared presumptively dead under Family Code Article 41 to invoke the defense under Revised Penal Code Article 349.
- Moral Damages Award
- Whether Tina is entitled to moral damages for bigamy, notwithstanding the exclusion of bigamy from Civil Code Article 2219’s enumerated offenses.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)