Case Summary (G.R. No. 150758)

Judicial Declaration of Nullity and Criminal Liability for Bigamy

The case addresses the implications of a judicial declaration of nullity of a second marriage based on psychological incapacity concerning an individual's criminal liability for bigamy. The ruling establishes that such a declaration does not retroactively affect the validity of the marriage in the context of the Philippines' penal laws. Consequently, an individual who enters into a second marriage while still legally married is criminally liable for bigamy, regardless of any subsequent declaration that the second marriage is void ab initio due to psychological incapacity.

• The court ruled that a judicial declaration of nullity does not retroactively affect criminal liability for bigamy.
• An individual remains liable for bigamy if they contract a second marriage while still legally married.

Background of the Case

Veronico Tenebro married Leticia Ancajas on April 10, 1990, while he was still married to Hilda Villareyes, whom he had married on November 10, 1986. After revealing his prior marriage to Ancajas, Tenebro left her to cohabit with Villareyes. Subsequently, he married Nilda Villegas on January 25, 1993. Ancajas filed a complaint for bigamy after confirming Tenebro's first marriage.

• Tenebro married Ancajas while still married to Villareyes.
• Ancajas filed a bigamy complaint after learning of Tenebro's previous marriage.

Elements of Bigamy Under Philippine Law

The elements of bigamy, as defined under Article 349 of the Revised Penal Code, include: (1) the offender has been legally married; (2) the first marriage has not been legally dissolved; (3) the offender contracts a second marriage; and (4) the second marriage has all the essential requisites for validity. The court found that all elements were satisfied in Tenebro's case.

• The elements of bigamy include prior legal marriage, undissolved first marriage, contracting a second marriage, and validity of the second marriage.
• The court determined that all elements were present in Tenebro's actions.

Petitioner’s Defense and Its Rejection

Tenebro's defense was twofold: he denied the existence of his first marriage and argued that the subsequent declaration of nullity of his second marriage retroactively negated the crime of bigamy. The court rejected both arguments, citing sufficient evidence of the first marriage and clarifying that the declaration of nullity does not negate criminal liability.

• Tenebro denied his first marriage and claimed the second marriage's nullity negated bigamy.
• The court found sufficient evidence of the first marriage and rejected the retroactive effect of the nullity declaration.

Evidence of the First Marriage

The prosecution presented a marriage contract and a letter from Villareyes confirming her marriage to Tenebro. In contrast, Tenebro provided certifications from the National Statistics Office and the City Civil Registry, which only indicated a lack of records, not the absence of marriage. The court emphasized that the marriage contract served as conclusive evidence of the first marriage.

• The prosecution provided a marriage contract and a letter confirming the first marriage.
• Tenebro's evidence did not sufficiently challenge the validity of the marriage contract.

The Effect of Psychological Incapacity on Marriage Validity

The court addressed Tenebro's argument regarding the effects of the judicial declaration of nullity based on psychological incapacity. It clarified that such a declaration does not retroactively affect the validity of the marriage concerning criminal liability for bigamy. The law penalizes the act of contracting a second marriage while a valid marriage exists, regardless of subsequent declarations.

• The court ruled that psychological incapacity does not retroactively affect marriage validity for bigamy.
• The law penalizes contracting a second marriage while a valid marriage exists.

Conclusion on Criminal Liability

The cou...continue reading