G.R. No. L-23893 - Villa Ray Transit Inc. vs. Ferrer

From 1974 to 1978, petitioner Lucio Morigo y Cacho and Lucia Barrete were boardmates at Catalina Tortor’s house in Tagbilaran City, Bohol; they lost contact after school year 1977–78.
In 1984, Lucia reestablished correspondence from Singapore; they became sweethearts. In 1990, Lucia returned to the Philippines, they agreed to wed, and on August 30, 1990 they married at the Iglesia Filipina Independiente in Pilar, Bohol. Lucia left for Canada on September 8, 1990.

On August 19, 1991, Lucia filed a divorce petition in the Ontario Court (General Division), which was granted on January 17, 1992 and took effect February 17, 1992.
The RTC and CA later held that a foreign court where neither spouse is domiciled lacks jurisdiction to divorce for Philippine purposes, and the decree is not recognized here.

On October 4, 1992, Lucio married Maria Jececha Limbago at the Virgen sa Barangay Parish in Tagbilaran City.
On October 19, 1993, he was charged with bigamy (RTC, Criminal Case No. 8688); he pleaded not guilty, was convicted on August 5, 1996 and sentenced to seven months of prisión correccional as minimum to six years and one day of prisión mayor as maximum.

While the CA appeal (CA-G.R.CR No. 20700) was pending, on October 23, 1997 the RTC of Bohol, Branch 1 (Civil Case No. 6020) declared the August 30, 1990 marriage void ab initio for lack of a solemnizing officer; the decision became final.
On October 21, 1999, the Court of Appeals affirmed the bigamy conviction; on September 25, 2000, it denied petitioner’s motion for reconsideration by a split vote, with a dissent noting that a void ab initio marriage never existed and cannot ground bigamy. Petitioner then filed a petition for review on certiorari with the Supreme Court.

Whether the Court of Appeals erred in holding that criminal intent and good faith are not indispensable under the Revised Penal Code and in failing to appreciate petitioner’s lack of criminal intent.
Whether the doctrine in People v. Bitdu is applicable to the case at bar.
Whether all circumstances favoring the accused’s innocence must be taken into account in proving guilt beyond reasonable doubt.