Case Summary (G.R. No. 224742)
Procedural History
Prudencio and Arlene's marriage was solemnized on April 8, 1994. In 2007, Prudencio abandoned his family. In December 2009, Arlene discovered that Prudencio had married Jean Basan. Subsequently, Arlene filed a complaint against Prudencio for bigamy pursuant to Article 349 of the Revised Penal Code. Prudencio was convicted of bigamy by the trial court in March 2012, which found that all the elements of the crime were present. Prudencio appealed, but the Court of Appeals affirmed the conviction in June 2015 and modified the penalty. After a motion for reconsideration was denied in April 2016, Prudencio filed a petition for review on certiorari.
Legal Standards
The pertinent law regarding bigamy in this case is found in Article 349 of the Revised Penal Code. Additionally, Article 40 of the Family Code asserts that a judicial declaration of the absolute nullity of a previous marriage is required before any subsequent marriage can be valid.
Argument of the Petitioner
Prudencio argued that his marriage to Arlene was void because the marriage contract lacked the signature of the solemnizing officer. He further contended that he acted in good faith, believing he could remarry based on a Certificate of No Marriage Record issued by the National Statistics Office. Moreover, he sought dismissal of the case due to an Affidavit of Desistance executed by Arlene after their reconciliation.
Court's Findings
The trial court initially rejected Prudencio's claims regarding the voidness of his marriage, as evidence showed the marriage had been duly solemnized and acknowledged by both parties. The court highlighted that mere discrepancies in documentation do not invalidate a marriage when other corroborating evidence exists.
Court of Appeals' Ruling
The Court of Appeals upheld the trial court's findings, emphasizing that the absence of the solemnizing officer’s signature does not render the marriage void, and reiterated that only a competent court can declare a marriage void. The appellate court maintained that the Affidavit of Desistance did not negate the elements of bigamy and was deemed of no probative value due to its timing.
Supreme Court's Decision
The Supreme Court affirmed the decision of the Court of Appeals, concluding that Prudencio could not unilaterally void his marriage with Arlene. It reiterated that a judicial declaration is necessary for marital nullity before see
...continue readingCase Syllabus (G.R. No. 224742)
Case Overview
- The case involves a Verified Petition for Review on Certiorari filed by Prudencio De Guzman y Jumaquio (Petitioner) challenging the Court of Appeals' decisions regarding his conviction for bigamy.
- The Supreme Court's ruling emphasizes the necessity of a judicial declaration of nullity for the purpose of remarriage.
Background of the Case
- Prudencio and Arlene De Guzman were married on April 8, 1994, in Quezon City, solemnized by Judge Julieto P. Tabiolo with Marriage License No. 1031606.
- In 2007, Prudencio abandoned Arlene and their children.
- In December 2009, Arlene discovered that Prudencio had married Jean Basan in Las Pinas City on December 17, 2009.
Legal Proceedings
- Arlene filed a Complaint for bigamy against Prudencio under Article 349 of the Revised Penal Code.
- The Information charged Prudencio with contracting a second marriage while still legally married to Arlene.
Trial Court Proceedings
- Prudencio pleaded not guilty and argued that his marriage to Arlene was void due to a missing signature of the solemnizing officer on the marriage contract.
- The trial court dismissed Prudencio's defense, citing a signed copy of the marriage contract at the Local Civil Registrar and evidence corroborating the existence of the marriage.
- The trial court ruled that Prudencio could not unilaterally declare his marriage void, as only the courts possess that power.
Trial Court Decision
- The trial cou