G.R. No. 200233 - Santiago vs. People

On 29 July 1997, petitioner Leonila G. Santiago, a 43-year-old widow, married Nicanor F. Santos, despite his subsisting marriage to Estela Galang since 2 June 1974.
Four months later, the People filed an Information for bigamy against petitioner and Santos; petitioner pleaded not guilty, while Santos evaded trial and later died.

Petitioner claimed she believed Santos to be single and argued that their marriage was void for lack of a marriage license under Article 34 of the Family Code.
Eleven years into the case, Estela Galang testified she had introduced herself as Santos’s legal wife to petitioner in March and April 1997—before petitioner’s marriage—an account petitioner denied.

The RTC found petitioner knew of the first marriage, disbelieved her claims, and treated their union as exempt from a license under Article 34 based on a misrepresented Certificate of Marriage; it convicted her of bigamy (Art. 349 RPC) and sentenced her to six months + one day of prision correccional to six years + one day of prision mayor.
On reconsideration, the RTC refused to nullify the marriage for lack of an annulment decree; the CA affirmed both conviction and sentence, rejecting petitioner’s knowledge and license arguments.

Whether petitioner, as second spouse, can be criminally liable in bigamy absent knowledge of the first marriage.
Whether the second marriage’s lack of a valid marriage license under Article 34, Family Code, rendered it void and thus deprived the prosecution of proving an essential requisite for bigamy.