Case Summary (G.R. No. 200233)
RTC Decision
The Regional Trial Court found that:
• Santos’s marriage to Galang was subsisting when he married Santiago.
• Santiago knew of that marriage, based on Galang’s testimony, family objections, and Santiago’s own credibility issues.
• The second marriage was validly solemnized without a license under Article 34, implying long cohabitation.
Santiago was convicted of bigamy as principal offender and sentenced to six months and one day to six years and one day of imprisonment. Her motion for reconsideration, arguing marriage nullity, was denied for lack of judicial annulment decree.
CA Decision
The Court of Appeals affirmed the RTC. It credited Galang over Santiago, upheld Santiago’s knowledge of the prior marriage, and dismissed the licensing argument as an impermissible collateral attack on marriage validity.
Issues Presented
- Whether Santiago could be charged as co-accused if unaware of Santos’s first marriage.
- Whether the prosecution must prove the validity of the second marriage.
- Whether absence of a marriage license renders the second marriage void and bars bigamy conviction.
Elements of Bigamy and Spouse Liability
Under Article 349 RPC, bigamy requires: (a) a valid first marriage; (b) its continued subsistence; (c) a subsequent marriage; and (d) validity of the subsequent union but for the subsisting first marriage. The second spouse incurs liability only if she knowingly enters the marriage, thereby acting as an accomplice (People v. Nepomuceno, Jr.; People v. Archilla).
Knowledge Requirement and Accomplice Liability
The Court upheld the lower courts’ factual findings that Santiago knew of the prior marriage, based on credible testimony and surrounding circumstances. Her awareness justified her inclusion as co-accused. However, as an accomplice rather than principal, her penalty must be reduced one degree under Article 52 RPC.
Validity of Second Marriage and License Requirement
Santiago consistently challenged the second marriage’s validity for lack of a license, asserting non-compliance with the five-year cohabitation exemption of Family Code Article 34. The lower courts declined to decide, but on review the Supreme Court found no evidence of five-year cohabitation before 1997. Their Certificate of Marriage falsely invoked Article 34’s exemption.
Fraudulent Certification and Legal Consequences
Santiago and Santos knowingly misrepresented cohabitation to the solemnizing officer, resulting in a certificate that bypassed the license requirement. Equity and public policy bar a party from relying on an illegal o
...continue readingCase Syllabus (G.R. No. 200233)
Procedural Posture
- Petition for Review on Certiorari filed by Leonila G. Santiago from the Decision and Resolution of the Court of Appeals (CA) in CA-G.R. CR No. 33566.
- CA affirmed the conviction of petitioner for bigamy by the Regional Trial Court (RTC) in Criminal Case No. 7232.
- Petition raises both factual issues (knowledge of the first marriage) and legal issues (validity of the second marriage without a license).
Facts
- Leonila G. Santiago (petitioner) was a 43-year-old widow when she married Nicanor F. Santos on 29 July 1997.
- Santos was still legally married to Estela Galang since 2 June 1974.
- Eleven years after the case began, Galang testified that she had informed petitioner in March and April 1997 that she was Santos’s lawful wife.
- Petitioner claimed she first met Galang only after her own marriage to Santos.
- The Certificate of Marriage between petitioner and Santos stated their union was solemnized under Article 34 of the Family Code, exempting them from a marriage license requirement.
RTC Ruling
- RTC found undisputed that Santos’s first marriage to Galang was subsisting at the time of the contested union.
- RTC credited Galang’s testimony that she had informed petitioner of the first marriage before 29 July 1997.
- RTC rejected petitioner’s affirmative defense of lack of knowledge.
- RTC held it could not declare the second marriage null and void absent a prior judicial decree of annulment.
- RTC convicted petitioner of bigamy under Article 349, RPC, and imposed an indeterminate penalty of six months and one day of prision correccional (minimum) to six years and one day of prision mayor (maximum).
CA Ruling
- CA affirmed the RTC’s factual findings and credibility assessments.
- CA dismissed petitioner’s challenge to th