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CENON R. TEVES v. PEOPLE

FACTS:

This case involves a petition filed by Cenon R. Teves seeking the reversal of the decision of the Court of Appeals, which upheld the decision of the Regional Trial Court finding him guilty of bigamy. Teves contracted a marriage with Thelma Jaime-Teves in November 1992. While Thelma was working overseas, she discovered that Teves had subsequently entered into a second marriage with Edita Calderon in December 2001. Thelma then filed a complaint accusing Teves of committing bigamy. Teves was accordingly charged with bigamy.

During the pendency of the case, the marriage between Teves and Thelma was declared null and void by another court. Despite this, the trial court still found Teves guilty of bigamy and sentenced him to imprisonment. Teves appealed the decision, contending that since his previous marriage had already been declared null and void, there was no existing valid marriage to consider in determining the crime of bigamy. However, the Court of Appeals affirmed the trial court's decision.

Teves filed a motion for reconsideration, but it was subsequently denied. Hence, he filed the present petition for review before the court seeking the reversal of the earlier decisions.

ISSUES:

  1. Whether the petitioner's criminal liability for bigamy is extinguished due to a subsequent declaration of nullity of his first marriage.

  2. Whether the defective Information filed by the prosecution affects the petitioner's conviction for bigamy.

RULING:

  1. Criminal liability is not extinguished by the subsequent declaration of nullity of the first marriage.

    • The Supreme Court held that a judicial declaration of nullity of a marriage is needed before one can contract a second marriage free from legal infirmity. The Family Code requires a final judgment declaring the previous marriage void before contracting a subsequent marriage. The crime of bigamy was completed when the second marriage was contracted with Edita on 10 December 2001 despite the earlier marriage with Thelma being legally subsisting until 2006. Thus, the petitioner's conviction for bigamy is affirmed.

  2. A defective Information does not affect the petitioner's conviction for bigamy.

    • The petitioner did not successfully prove the alleged defect in the Information filed against him. The court found that the Information sufficiently apprised the petitioner of the nature and cause of the accusation.

PRINCIPLES:

  1. Article 349 of the Revised Penal Code: Elements of bigamy.

  2. Requirement of Judicial Declaration: A judicial declaration of nullity of a previous marriage is necessary to contract a second valid marriage.

  3. Criminal Liability: Criminal culpability attaches upon the commission of the offense and remains until extinguished by law.

  4. Timing of Judicial Decisions: The nullity of the first marriage cannot retroact to absolve criminal liability incurred before the declaration.