Case Digest (G.R. No. 150758)
Facts:
- Veronico Tenebro married Hilda Villareyes on November 10, 1986.
- On April 10, 1990, Tenebro entered a second marriage with Leticia Ancajas, officiated by Judge Alfredo B. Perez, Jr.
- Tenebro and Ancajas cohabited until late 1991 when Tenebro revealed his prior marriage to Villareyes and left Ancajas.
- Tenebro married Nilda Villegas on January 25, 1993, before Judge German Lee, Jr.
- Ancajas discovered this third marriage, confirmed Tenebro's first marriage to Villareyes, and filed a bigamy complaint against him.
- Tenebro was arraigned in Criminal Case No. 013095-L and pleaded "not guilty."
- During the trial, Tenebro admitted to cohabiting with Villareyes but denied a valid marriage, claiming the marriage contract was signed for her to receive his seaman's allotment.
- The Regional Trial Court of Lapu-lapu City found Tenebro guilty of bigamy on November 10, 1997, sentencing him to four years and two months to eight years and one day of imprisonment.
- The Court of Appeals affirmed this decision, leading to Tenebro's petition for review.
Issue:
- (Unlock)
Ruling:
- The Court of Appeals did not err in affirming Tenebro's conviction for bigamy.
- The judicial declaration of nullity of the second marriage on the ground of psyc...(Unlock)
Ratio:
- The Supreme Court held that sufficient evidence was presented to prove Tenebro's marriage to Villareyes, including a certified copy of the marriage contract and a handwritten letter from Villareyes confirming the marriage.
- The defense's documents, attesting to the absence of a record of the marriage, were insufficient to invalidate the marriage contract.
- A marriage contract, as a public document, is admissible as the best evidence of its contents and should be given full faith and credence.
- The absence of a record does not invalidate a marriage if all requisites for its validity are present.
- The judicial declaration of nullity of the second marriage on the ground of psychological incapacity does not retroact to the date of the marriage for purposes of criminal liability under Philippine penal laws.
- The crime of bigamy is consummated upon contracting a second marriage during the subsistence of a valid first marriage.
- Penal laws protect the instit...continue reading
Case Digest (G.R. No. 150758)
Facts:
Veronico Tenebro, the petitioner, was initially married to Hilda Villareyes on November 10, 1986. Subsequently, on April 10, 1990, Tenebro entered into a second marriage with Leticia Ancajas, officiated by Judge Alfredo B. Perez, Jr. of the City Trial Court of Lapu-lapu City. Tenebro and Ancajas cohabited until late 1991, when Tenebro disclosed his prior marriage to Villareyes and left to live with her. On January 25, 1993, Tenebro contracted a third marriage with Nilda Villegas before Judge German Lee, Jr. of the Regional Trial Court of Cebu City, Branch 15. Upon discovering this third marriage, Ancajas confirmed Tenebro's marriage to Villareyes and subsequently filed a bigamy complaint against him. The case, docketed as Criminal Case No. 013095-L, led to Tenebro's arraignment, where he pleaded "not guilty." During the trial, Tenebro admitted to cohabiting with Villareyes but denied a valid marriage, claiming the marriage contract was signed solely for her to receive his seaman's allotment. Despite his defense, the Regional Trial Court of Lapu-lapu City, Branch 54, found Tenebro guilty of bigamy on November 10, 1997, sentencing him to an indeterminate penalty of four years and two months of prision correccional as minimum, to eight years and one day of prision mayor as maximum. The Court of Appeals affirmed this decision, leading to Tenebro's petition for review.
Issue:
- Did the Court of Appeals err in affirming Tenebro's conviction for bigamy despite the alleged non-existence of the first marriage and insufficient...