Title
Supreme Court
Marbella-Bobis vs. Bobis
Case
G.R. No. 138509
Decision Date
Jul 31, 2000
A man contracted multiple marriages without annulling the first, leading to a bigamy charge. The Supreme Court ruled that a pending civil case for nullity of the first marriage does not suspend the criminal case, emphasizing the need for a judicial declaration of nullity before remarrying.

Case Digest (G.R. No. 138509)
Expanded Legal Reasoning Model

Facts:

  • Marital history of respondent
    • On October 21, 1985, respondent married Maria Dulce B. Javier; no annulment, nullification, or termination followed.
    • On January 25, 1996, respondent contracted a second marriage with petitioner Imelda Marbella-Bobis and allegedly a third with Julia Sally Hernandez.
  • Criminal and civil proceedings
    • On February 25, 1998, petitioner filed a complaint-affidavit leading to Bigamy charges (Criminal Case No. Q98-75611, RTC Branch 226, Quezon City).
    • Respondent thereafter filed a civil action for judicial nullity of the first marriage (ground: lack of marriage license) and moved to suspend the bigamy proceedings as a prejudicial question.
    • The RTC granted suspension on December 29, 1998; motion for reconsideration was denied, prompting this petition for certiorari.

Issues:

  • Whether the filing of a civil action for declaration of nullity of a previous marriage constitutes a prejudicial question to a pending criminal case for bigamy.
  • Whether the RTC erred in suspending the bigamy proceedings pending resolution of the civil nullity action under Article 40 of the Family Code.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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