Case Digest (G.R. No. 14639) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 261666, petitioner Rommel Genio y Santos was charged with Bigamy under Article 349 of the Revised Penal Code after he allegedly married Magdalena Esler Genio on May 20, 2006, without having that marriage legally dissolved, and then contracted a second marriage to Maricar Santos Galapon on September 7, 2013, in Guimba, Nueva Ecija. The Information was filed on June 21, 2016, before the RTC of Guimba, Nueva Ecija. At trial, the prosecution offered as evidence the marriage certificates of both unions and the birth certificates of the children, and presented Magdalena as witness. She testified to the existence of the first marriage, its continued subsistence, and her discovery—through Facebook photos, personal visit, and official documents—of Rommel’s purported second marriage. Rommel admitted the authenticity of both certificates but contended that the second marriage was void ab initio for lack of a valid solemnization by the Municipal Mayor and absence of a proper cer... Case Digest (G.R. No. 14639) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Case Background
- Rommel Genio y Santos was charged with Bigamy under Article 349 of the Revised Penal Code by Information dated June 21, 2016, alleging he married Maricar Santos Galapon on September 7, 2013 while his first marriage to Magdalena Esler Genio (May 20, 2006) was subsisting.
- He pleaded “Not Guilty.” Pre-trial stipulations covered only the authenticity of the second Marriage Certificate. Trial court convicted him, and the Court of Appeals (CA) affirmed both the conviction (July 16, 2021) and denial of reconsideration (June 7, 2022).
- Prosecution’s Evidence
- Testimony of Magdalena Genio: she married Rommel in 2006, had three children, lived separately since 2013, and learned via Facebook and personal visit that he was cohabiting with Maricar, who was pregnant. She secured from the PSA the certified copy of the second Marriage Certificate and the child’s Birth Certificate.
- Documentary evidence admitted: Complaint-Affidavit of Magdalena; first Marriage Certificate; birth certificates of first marriage children; Maricar’s child’s Birth Certificate; and certified copy of the second Marriage Certificate.
- Defense’s Evidence
- Rommel admitted both marriages but argued the second was void ab initio for lack of solemnization by the Municipal Mayor and absence of a proper marriage ceremony.
- Witnesses Maricar (second wife), Myra Galapon and Gloria Floria (relatives) uniformly testified: the solemnizing officer was the Civil Registrar, not the Mayor; no exchange of vows or rings before a duly authorized solemnizing officer; only signing of the contract at Maricar’s residence with relatives attending.
Issues:
- Whether the prosecution proved beyond reasonable doubt the fourth element of Bigamy—that the second marriage had all essential and formal requisites for validity—when it relied on the prima facie presumption from the PSA Marriage Certificate.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)