G.R. No. L-38095 - People vs. Melendres

Petitioner Samson R. Pacasum (Pacasum) and respondent Atty. Marietta D. Zamoranos (Zamoranos) married on December 28, 1992.
Prior to that marriage, Zamoranos converted to Islam and married Jesus De Guzman on July 30, 1982.

On December 14, 2004, Pacasum filed an administrative complaint with the Civil Service Commission (CSC) for bigamy, alleging Zamoranos’ marriage to De Guzman was still subsisting.
Zamoranos answered by submitting the Shari’a Circuit Court Decree of Divorce (June 18, 1992) issued in Basilan, evidencing the dissolution of her first marriage under Presidential Decree No. 1083 (the Muslim Code).
The CSC dismissed Pacasum’s complaint, holding that he failed to challenge the existence or validity of the divorce decree.
On appeal, the Court of Appeals (CA) initially ruled in favor of Pacasum but, upon reconsideration, reversed itself, finding that a collateral attack on a final Shari’a divorce decree in an administrative forum was not allowed.
Pacasum then filed a petition for review on certiorari with the Supreme Court.

Whether the Shari’a Circuit Court had jurisdiction to dissolve Zamoranos’ first marriage under the Muslim Code.
Whether the final Shari’a divorce decree could be collaterally attacked in an administrative complaint before the CSC, thereby rendering Zamoranos’ subsequent marriage bigamous.