G.R. No. 206284 - Sarto y Misalucha vs. People

On 3 October 2007, petitioner Redante Sarto y Misalucha was charged with bigamy for allegedly contracting two marriages without legally dissolving the first.
The first marriage was with Maria Socorro G. Negrete, solemnized on 31 August 1984 in Angono, Rizal. The second marriage was with Fe R. Aguila, contracted on 29 December 1998 at the Peñafrancia Basilica Minore in Naga City.
The criminal complaint was filed by Fe on 4 June 2007.

At arraignment on 3 December 2007, Redante pleaded not guilty. During pre-trial, he admitted the two marriages but defended that the first marriage was legally dissolved by divorce abroad (Canada).
The RTC allowed the taking of Maria Socorro’s deposition before she left the country, which was conducted on 28 May 2008.
On 22 August 2008, the prosecution moved for a reverse trial because of Redante’s admissions; the defense was ordered to present their evidence first.

Maria Socorro became a Canadian citizen on 1 April 1988.
Divorce was granted by the Supreme Court of British Columbia on 1 November 1988.
The couple attempted reconciliation in 1992, resulting in a daughter born in 1993, but ultimately failed.
Redante’s second marriage to Fe occurred in December 1998; they lived together and had children.
Maria Socorro remarried Douglas Alexander Campbell in Canada on 5 August 2000.

A Certificate of Divorce issued on 14 January 2008 by the Supreme Court of British Columbia was presented.

Marriage contracts between Redante and Maria Socorro, and between Redante and Fe, were submitted to prove the two marriages.
The prosecution adopted the divorce certificate to show it was secured only in 2008, after the second marriage.
Testimonial evidence was waived.

The RTC found Redante guilty beyond reasonable doubt of bigamy due to failure to prove legal dissolution of the first marriage.
The judgment emphasized:

No competent evidence presented on the divorce decree itself or proof of Maria Socorro’s naturalization date.
No judicial recognition of the foreign divorce in the Philippines.

The CA affirmed the RTC judgment, holding that the lack of proof of the divorce decree and its conformity to the foreign law rendered the defense untenable.
Reconsideration was denied on 6 March 2013.

The OSG filed a manifestation advocating for Redante’s acquittal, arguing that the Canadian citizenship certificate (submitted belatedly as a photocopy) showed Maria Socorro was a citizen since 1 April 1988, thus making the 1988 divorce valid.
OSG contended that substantial rights should prevail over procedural lapses.

Whether the trial court and Court of Appeals erred in finding petitioner Redante Sarto y Misalucha guilty beyond reasonable doubt of bigamy despite his claim that his first marriage was legally dissolved by a foreign divorce.