Case Summary (G.R. No. 159031)
Relevant Facts
On February 16, 1968, Noel Lasanas and Socorro Patingo were married without a marriage license. Although they reaffirmed their marriage on August 27, 1980, through a religious ceremony, no proper documentation was executed to legitimize the marriage legally. The couple separated de facto in 1982 due to irreconcilable differences. On December 27, 1993, Lasanas married Josefa Eslaban based on the presumption that his first marriage was void due to the lack of formal legal requirements.
Judicial Proceedings
Lasanas filed a complaint for annulment against Socorro, alleging deceit, misrepresentations, and infidelity, but his complaint was dismissed by the RTC, which upheld the validity of his marriage to Socorro. Subsequently, Socorro charged Lasanas with bigamy in 1998, leading to his indictment in Criminal Case No. 49808. The RTC convicted him of bigamy on October 30, 2000, sentencing him to an indeterminate prison term. The CA affirmed this decision on August 29, 2002.
Legal Issues
Lasanas contended that because he believed his first marriage was void, the elements of bigamy were not met. He argued that a judicial declaration of nullity was necessary before contracting a subsequent marriage, but he did not secure one until after marrying Josefa. He also claimed good faith and lack of criminal intent as defenses against the charge of bigamy.
Ruling of the Court
The Supreme Court upheld the findings of the RTC and the CA. It affirmed that, despite the initial marriage being void for lack of a marriage license, Lasanas was still guilty of bigamy. The Court reiterated that a judicial declaration of nullity of the first marriage must be obtained before contracting a subsequent marriage. The ruling emphasized that individuals cannot determine the validity of t
...continue readingCase Syllabus (G.R. No. 159031)
The Case
- The petitioner, Noel A. Lasanas, seeks to reverse the decision promulgated on August 29, 2002, by the Court of Appeals (CA), which affirmed his conviction for bigamy as defined under Article 349 of the Revised Penal Code.
- The conviction arises from a marriage contracted without the required judicial declaration of nullity of his first marriage, which was deemed void due to the absence of a marriage license.
Antecedents
- On February 16, 1968, Lasanas married Socorro Patingo in a ceremony officiated by Judge Carlos B. Salazar, lacking a marriage license.
- No affidavit of cohabitation was executed to excuse this absence.
- They reaffirmed their marriage in a religious ceremony on August 27, 1980, without presenting a marriage license or affidavit of cohabitation.
- The couple separated de facto in 1982 due to irreconcilable differences.
- On December 27, 1993, Lasanas married Josefa Eslaban in a religious ceremony, falsely indicating his civil status as single on the marriage certificate.
- In 1996, Lasanas filed for annulment against Socorro, alleging deception and marital breaches, but the case was dismissed in 1998, affirming the validity of his marriage to Socorro.
Criminal Proceedings
- In October 1998, Socorro filed a complaint against Lasanas for bigamy with the Office of the City Prosecutor.
- Lasanas was formally