Case Digest (G.R. No. L-26112) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In an Information dated April 29, 2008, the Office of the City Prosecutor of Manila charged Norberto Abella Vitangcol with bigamy under Article 349 of the Revised Penal Code for contracting a second marriage with Alice G. Eduardo on December 4, 1994 at the Manila Cathedral while still legally married to Gina M. Gaerlan since July 17, 1987. The marriage contract of the first union, duly executed and bearing Marriage License No. 8683519, along with petitioner’s authenticated signature, was presented by the prosecution as positive proof of a valid, subsisting marriage. From the second marriage, petitioner and Alice had three children. Rumors of petitioner’s prior marriage prompted Alice to verify the first marriage through the civil registry and eventually file the bigamy complaint in 2008. On September 1, 2010, Branch 25 of the Regional Trial Court of Manila found petitioner guilty of bigamy, sentencing him to six years and one day to twelve years of prision mayor. On July 18, 201 Case Digest (G.R. No. L-26112) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural History
- In an Information dated April 29, 2008, Norberto A. Vitangcol was charged with bigamy under Article 349 of the Revised Penal Code for contracting a second marriage on December 4, 1994 while his first marriage to Gina M. Gaerlan remained subsisting.
- At arraignment, Vitangcol pleaded not guilty, and trial ensued in Branch 25 of the Regional Trial Court (RTC) of Manila.
- First and Second Marriages
- First marriage: On July 17, 1987, Vitangcol married Gina M. Gaerlan, as evidenced by a marriage contract registered with the National Statistics Office.
- Second marriage: On December 4, 1994, Vitangcol married Alice G. Eduardo at Manila Cathedral; the union produced three children.
- Defense and Procedural Developments
- Vitangcol claimed no valid first marriage license existed and secured a certification from the Civil Registrar of Imus, Cavite, stating no record of Marriage License No. 8683519. He argued this proved the first marriage void ab initio.
- RTC Decision (Sept. 1, 2010): Convicted Vitangcol of bigamy and imposed six years and one day to twelve years of prision mayor.
- Court of Appeals Decision (July 18, 2012): Affirmed conviction but modified sentence to an indeterminate penalty of two years and four months of prision correccional as minimum to eight years and one day of prision mayor as maximum. Motion for reconsideration was denied on June 3, 2013. Vitangcol then filed a Petition for Review on Certiorari with the Supreme Court.
Issues:
- Whether a certification of “no record” of a marriage license suffices to prove the nullity of petitioner’s first marriage and negate the first element of bigamy.
- Whether a judicial declaration of nullity of the first marriage is a precondition to contracting a subsequent marriage and thus an implicit element of the crime of bigamy under Article 349, RPC.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)