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LEONILA G. SANTIAGO v. PEOPLE

FACTS:

Four months after their marriage, Leonila G. Santiago and Nicanor F. Santos were faced with an information for bigamy. Santiago pleaded not guilty while Santos escaped the criminal suit. The prosecution presented evidence that Santos, who was already married to Estela Galang, asked Santiago to marry him. Despite the advice of her family, Santiago married Santos. Santiago claimed that she believed Santos was single at the time of their marriage and argued that their marriage was void due to the lack of a marriage license. The Regional Trial Court (RTC) rejected Santiago's defense and convicted her of bigamy. The RTC ruled that their marriage was celebrated without a need for a marriage license based on the Certificate of Marriage. Santiago filed a motion for reconsideration, but it was denied by the RTC. Santiago appealed to the Court of Appeals (CA), claiming that her conviction was not based on proof beyond reasonable doubt. The CA affirmed her conviction. Santiago filed a Petition for Review on Certiorari with the Supreme Court, reiterating her arguments.

ISSUES:

  1. Whether the petitioner, who was unaware of her spouse’s previous marriage, can be held liable for bigamy.

  2. Whether a valid second marriage must be proven by the prosecution beyond reasonable doubt to sustain a conviction for bigamy.

  3. Whether the second marriage of the petitioner is void due to the absence of a marriage license, thereby affecting the conviction for bigamy.

  4. Whether the petitioner, as the second spouse, can be considered a principal or an accomplice to the crime of bigamy.

RULING:

  1. The Court reaffirmed that the petitioner knew about the first valid marriage of Santos and thus can be held liable for bigamy.

  2. For a conviction of bigamy, it is essential that the second marriage has all the essential requisites for validity. However, in this case, the petitioner argued the invalidity of her marriage due to the absence of a marriage license.

  3. The Court found that the second marriage was indeed conducted without a proper marriage license and based on misrepresentation of the required five-year cohabitation. Moreover, since the petitioner was a party to the unlawful act of faking the requisite cohabitation period, she could not use her illegal act to escape criminal conviction.

  4. The Court concluded that the petitioner, being aware of the existing prior marriage and participating in misrepresenting to obtain the second marriage, is considered an accomplice, not a principal, in the crime of bigamy.

PRINCIPLES:

  1. Bigamy under Article 349 of the Revised Penal Code: The crime of bigamy involves contracting a second marriage while the first marriage is still valid and subsisting.

  2. Essentials for Bigamy Conviction: The second marriage must have all essential requisites for validity except for the subsistence of the first marriage.

  3. Knowledge of Prior Marriage: For a second spouse to be included as a co-accused in bigamy, they must have knowledge of the subsisting previous marriage.

  4. Accomplice Liability: A person who knowingly consents to marry someone already legally bound in wedlock is guilty as an accomplice in bigamy.

  5. Defense of Invalid Second Marriage: A claim that the second marriage is void ab initio due to the absence of a marriage license cannot be used to escape liability if the accused participated in the illegality.

  6. Ex Turpi Causa Principle: No court will lend its aid to one who has become a party to an illegal act upon which their cause of action is founded.

  7. Sanctity of Marriage: The State protects the integrity and permanence of marital bonds, discouraging fraudulent acts meant to undermine this sanctity.