G.R. No. 257783 , August 20, 2025
ARNALDO PUNZAL Y DARIA, PETITIONER, vs. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

An Information for bigamy under Article 349 of the Revised Penal Code was filed against petitioner Arnaldo Punzal y Daria on August 13, 2007. The prosecution presented two marriage certificates: the first showed Arnaldo married Catherine Mercado del Rosario on August 8, 1999, in Noveleta, Cavite; the second showed he married private complainant Perlita T. Guevan on January 5, 2002, in Sta. Maria, Bulacan. For his defense, Arnaldo claimed: (1) he was not the same person as the groom in the first marriage certificate due to differing dates of birth; (2) he never resided in Cavite as indicated in that certificate; and (3) the first marriage was null and void for want of a marriage license. He also argued that no bigamy was committed because his marriage with Perlita was subsequently declared null and void. The Regional Trial Court (RTC) found Arnaldo guilty of bigamy, a decision affirmed by the Court of Appeals (CA). The CA noted that the judicial decree nullifying the second marriage with Perlita was based precisely on the ground of Arnaldo’s prior marriage, which reinforced the prosecution’s case, and that the private complainant’s desistance did not bar the prosecution.

ISSUE

1. Whether the prosecution sufficiently proved the validity and subsistence of the alleged first marriage of Arnaldo with Catherine Mercado del Rosario.
2. Whether Arnaldo’s conviction for bigamy should stand.

RULING

The Supreme Court granted the petition and reversed the convictions. On the first issue, the Court held that the prosecution failed to prove the validity and subsistence of the first marriage, an indispensable element of bigamy. The evidence established the absence of a marriage license for the first marriage: the prosecution’s own witness confirmed no license was attached to the marriage certificate, and the defense presented a Certification from the Local Civil Registrar of Imus, Cavite stating no record existed of any marriage license issued to Arnaldo and Catherine. Citing jurisprudence (Alcantara v. Alcantara, Republic v. CA, Nicdao Cariño v. Yee Cariño, and Pulido v. People), the Court ruled that the absence of a marriage license, save for statutory exceptions, renders a marriage void ab initio. Furthermore, a void ab initio marriage constitutes a valid defense in a bigamy prosecution even without a prior judicial declaration of nullity, as it negates the element of a valid, subsisting first marriage. The Court also found material discrepancies between Arnaldo’s personal circumstances and those in the first marriage certificate, which were disregarded by the lower courts, warranting a review of factual issues to prevent a miscarriage of justice. Since the first marriage was void ab initio for lack of a license, the crime of bigamy was not committed. Consequently, the second issue was rendered moot, and Arnaldo’s conviction was set aside.