G.R. No. L-15632 - People vs. Archilla

On March 6, 1959, charges of bigamy were filed before the Court of First Instance of Quezon province against defendants Jose Luis Archilla (alias Chino Santos) and Alfreda Roberts.
The complaint alleged that on or about May 26, 1958, in Lucena, Quezon, Jose Luis Archilla, who was still lawfully married to Luz Mat Castro de Archilla, unlawfully contracted a second marriage with Alfreda Roberts.
It was specifically stated that Alfreda Roberts, by entering into the marriage with Archilla, did so with knowledge that his previous marriage remained valid and subsisting.

After entering a plea of not guilty, Alfreda Roberts, through her counsel, moved to quash the information filed against her on the ground that the complaint did not adequately allege all the necessary elements of the offense of bigamy in her case.
The trial court granted her motion to quash with respect to her by reasoning that since the complaint did not allege her marriage to Archilla as her second marriage, it could not constitute bigamy against her.
The order dismissing the charge against her was issued on May 5, 1959.

The prosecution appealed the decision, contending that the lower court erred by quashing the information, arguing that even though the complaint did not state that her marriage to Archilla was her second marriage, her act of contracting the marriage with knowledge that his previous marriage was still subsisting amounted to her indispensable cooperation in the commission of bigamy.
The appellant’s argument further maintained that accepting her motion to quash would effectively amount to her acquittal and, if allowed on appeal, could subject her to punishment twice for the same offense, thereby invoking the protection against double jeopardy.
A significant contention was raised regarding whether the accused could now invoke the plea of double jeopardy after having induced the trial court to quash the information—a move that the prosecution argued was inconsistent with her prior stance in the lower court.

The majority held that once the accused sustains a theory in the lower court (arguing that the facts did not constitute the offense), she cannot later invoke double jeopardy to avoid facing prosecution on an information she previously branded as insufficient.
The Court underscored the principle of judicial estoppel, noting that a party may not take inconsistent positions throughout the litigation process.
The decision referenced the parallel case of People vs. Acierto to illustrate that an accused who initially challenges jurisdiction or sufficiency of allegation cannot later change positions to invoke double jeopardy under different legal theories.

Whether the lower court erred in quashing the information against Alfreda Roberts on the ground that the complaint failed to allege that her marriage to Jose Luis Archilla was her second marriage.
Whether the absence of an explicit allegation regarding a “second marriage” negated the possibility of establishing the offense of bigamy when knowledge of a subsisting prior marriage was present.

Whether Alfreda Roberts may invoke the plea of double jeopardy on appeal after having argued in the lower court that no crime was committed against her due to insufficient allegations.
Whether her change in theory – implicit in her current defense versus her previous stance – violates the doctrine of judicial estoppel by adopting inconsistent positions in different stages of the proceedings.

Adequacy of the Allegations in Establishing Criminal Liability as an Accomplice

Whether the information, as charged, is sufficient to prosecute her as an accomplice in bigamy, given that it emphasizes her awareness of Archilla’s prior valid marriage.
Whether the elements of bigamy are satisfied by the demonstration of her knowledge and subsequent action, notwithstanding the specific absence of an explicit statement about her own marriage being a “second” one.