Leonila Santiago v. People of the PH

GR 200233      

July 15, 2015

Facts:

            4 months after solemnization of marriage, Leonila (petitioner) and Nicanor Santiago were served an information for Bigamy for the prosecution adduced that Nicaonor was still married to Estela when he entered into the 2^nd marriage; he was able to escape while petitioner pleaded ‘not guilty’ relying on the fact that when she married him, she thought he was single. She soon averred that their marriage was void due to lack of marriage license, wherein she should not then be charged with bigamy. 11 years after inception if criminal case, Estela Galang, the first wife, testified for the prosecution. She alleged that she had met petitioner and introduced herself as the legal wife. Petitioner denied allegation and stated that she met Estela only after she had already married Nicanor.

            Issue:   W/N petitioner is co-accused in the instant case of Bigamy.

                        W/N marriage between Leonila and Nicanor is valid

Held:

            Lower courts consistently found that petitioner indeed knew of the first marriage as shown by the totality of the following circumstances: (1) when Nicanor was courting and visiting petitioner in the house of her in-laws, they openly showed their disapproval of him (2) it was incredible for a learned person like petitioner to not know of his true civil status (3) Estela, who was the more credible witness, compared to petitioner who had various inconsistent testimonies, straightforwardly testified that she had already told petitioner on two occasions that the former was the legal wife of Nicanor. In People v. Archilla, knowledge of the second wife of the fact of her spouse’s existing prior marriage, constitutes an indispensable cooperation in the commission of Bigamy, which makes her responsible as an accomplice. She is not co-accused. She is guilty of Bigamy as an accomplice thereby sentenced to 6m arresto mayor to 4y prision correccional.