The Supreme Court in Santiago v. People affirmed the bigamy conviction of Leonila G. Santiago, despite arguments that her marriage to Nicanor F. Santos was void due to the absence of a valid marriage license. The Court ruled that Santiago could not benefit from her own deception, as she had misrepresented her eligibility to marry Santos without a license. This case highlights the principle that individuals cannot use their illegal acts to evade criminal liability, particularly in matters concerning marriage, which the Constitution protects as an inviolable social institution.

Deceptive Unions: Can a Void Marriage Save You from a Bigamy Charge?

The case revolves around Leonila Santiago’s marriage to Nicanor Santos, who was already married to Estela Galang. Santiago was charged with bigamy, but she argued that her marriage to Santos was void because they did not have a marriage license, nor did they meet the requirements for exemption under Article 34 of the Family Code. This article allows a marriage without a license if the couple has lived together as husband and wife for at least five years. Santiago and Santos falsely claimed they met this requirement to get married.

The central legal question is whether a person can be convicted of bigamy if their second marriage is later found to be void. To answer this, we must understand the elements of bigamy as defined in Montañez v. Cipriano:

The elements of the crime of bigamy are: (a) the offender has been legally married; (b) the marriage has not been legally dissolved x x x; (c) that he contracts a second or subsequent marriage; and (d) the second or subsequent marriage has all the essential requisites for validity.

The twist here is that Santiago argued her second marriage lacked the essential requisites for validity, specifically the marriage license. However, the Court scrutinized her actions and the misrepresentation she made to enter that marriage. In bigamy cases, the knowledge of the second spouse about the existing prior marriage of their partner is crucial. The Supreme Court, referring to People v. Nepomuceno, Jr., clarified:

In the crime of bigamy, both the first and second spouses may be the offended parties depending on the circumstances, as when the second spouse married the accused without being aware of his previous marriage. Only if the second spouse had knowledge of the previous undissolved marriage of the accused could she be included in the information as a co-accused.

Both the RTC and the CA found that Santiago knew of Santos’s first marriage to Galang. The courts highlighted the disapproval of Santos by Santiago’s in-laws, the incredulity of Santiago’s ignorance given her education, and Galang’s credible testimony that she had informed Santiago about her marriage to Santos. These findings led the Court to conclude that Santiago was indeed aware of the prior existing marriage.

The Court, however, modified the lower courts’ decision regarding the penalty. While Santiago was correctly charged with bigamy, her role was that of an accomplice, not a principal. People v. Archilla clarifies that the second spouse, knowing about the existing prior marriage, becomes an accomplice in the bigamous marriage. As an accomplice, Santiago’s sentence was reduced to an indeterminate penalty of six months of arresto mayor as minimum to four years of prision correccional as maximum.

A key aspect of this case is the fact that the marriage between Santiago and Santos was solemnized without a marriage license, purportedly under Article 34 of the Family Code. However, they falsely claimed they had lived together as husband and wife for at least five years, which would have exempted them from the license requirement. In fact, they knew each other for less than four years.

No license shall be necessary for the marriage of a man and a woman who have lived together as husband and wife for at least five years and without any legal impediment to marry each other. The contracting parties shall state the foregoing facts in an affidavit before any person authorized by law to administer oaths. The solemnizing officer shall also state under oath that he ascertained the qualifications of the contracting parties are found no legal impediment to the marriage.

The Court emphasized that Santiago could not benefit from her misrepresentation. The Certificate of Marriage contained a false statement that they were eligible to marry without a license. The Supreme Court cited the case of Tenebro v. Court of Appeals:

[T]he State’s penal laws on bigamy should not be rendered nugatory by allowing individuals “to deliberately ensure that each marital contract be flawed in some manner, and to thus escape the consequences of contracting multiple marriages, while beguiling throngs of hapless women with the promise of futurity and commitment.”

The Court invoked the principle that no court will aid someone who has consciously participated in an illegal act. Since Santiago’s defense was based on the illegality of her marriage to Santos, an illegality she herself helped create, the Court refused to grant her relief. This principle is rooted in the concept of ex turpi causa non oritur actio, which means no cause of action arises from an immoral or illegal act.

Santiago invoked the case of People v. De Lara, where the accused was acquitted of bigamy because the marriage license was issued after the marriage ceremony. However, the Supreme Court distinguished De Lara from Santiago’s case, noting that Santiago and Santos had actively falsified documents to secure their marriage. This made her situation fundamentally different, as it involved deliberate deception to circumvent marriage laws.

The Supreme Court’s decision underscores the constitutional protection afforded to marriage as an inviolable social institution. Allowing individuals to manipulate marital requirements to evade bigamy charges would undermine this fundamental principle. The Court’s judgment emphasizes the sanctity of marriage and aims to prevent parties from deliberately creating flawed marital contracts to escape the consequences of bigamy. It sends a clear message that the Court will not condone or assist in schemes designed to undermine the institution of marriage.

FAQs

What was the key issue in this case?	The key issue was whether Leonila Santiago could be convicted of bigamy when she argued that her second marriage was void due to the lack of a valid marriage license.
What is bigamy under the Revised Penal Code?	Bigamy is the act of contracting a second or subsequent marriage before the first marriage has been legally dissolved or before the absent spouse has been declared presumptively dead by a court.
What are the elements of bigamy?	The elements are: a legally married offender, the first marriage not legally dissolved, contracting a second or subsequent marriage, and the second marriage having all essential requisites for validity.
What is Article 34 of the Family Code?	Article 34 of the Family Code provides an exception to the marriage license requirement for couples who have lived together as husband and wife for at least five years.
Why was Santiago convicted despite the argument of a void marriage?	Santiago was convicted because she misrepresented that she met the requirements of Article 34 and could not benefit from her own fraudulent actions.
What was Santiago’s role in the commission of the crime?	Santiago was found to be an accomplice in the crime of bigamy because she knowingly entered into a marriage with Santos, who was already married.
How did the Court modify the lower court’s decision?	The Court modified the penalty imposed, downgrading Santiago’s conviction from a principal to an accomplice, and adjusted her sentence accordingly.
What is the principle of ex turpi causa non oritur actio?	It means that no cause of action arises from an immoral or illegal act. This principle prevented Santiago from using her illegal marriage to escape criminal liability.
How does this case differ from People v. De Lara?	Unlike De Lara, where the marriage license was simply issued a day late, Santiago actively falsified information to secure her marriage, making her case distinct.

In conclusion, the Supreme Court’s decision in Santiago v. People reinforces the importance of upholding the sanctity of marriage and preventing individuals from exploiting legal loopholes through fraudulent means. The ruling serves as a stern warning against those who attempt to undermine the institution of marriage for personal gain.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: LEONILA G. SANTIAGO, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT., G.R. No. 200233, July 15, 2015