GR No.

200233
Leonila Santiago, Petitioner, vs. People of the Philippines, Respondent.
(Bigamy Case ng Playboy ug Danghag)

 RTC – convicted the petitioner and Santos of bigamy

 CA – affirmed the decision of RTC
 Hence a petition for certiorari

FACTS:

1. Nicanor F. Santos and Estela Galang were married since June 2, 1974
2. Santos (playboy) courted Santiago (43-year-old widow) and eventually they got married on July 29, 1997 despite
the advice of Santiago’s brother-in-law and parents-in-law that Santos was already married.
3. After their wedding, they were both charged with bigamy
4. Petitioner argued that she could not be included as accused in the crime of bigamy because she had been in the
belief that Santos was still single when they got married.
5. Petitioner also argued that for there to be a case of bigamy, her marriage with Santos should be proven by
prosecution to be valid; in this case, she argued that her marriage with Santos was void due to the lack of a
marriage license.
6. Estela Galang (Legal Wife) alleged that she had met the petitioner as early as March and April 1997, on which
she introduced herself to the petitioner as the legal wife of Santos.
7. Petitioner denied Galang’s allegation and averred that she only met Galang in August and September 1997, after
she married Santos.
8. The RTC appreciated the more credible statement of Galang and rejected the defense of the petitioner. RTC said
that it was incredible for a learned person like the petitioner to be easily duped by a person like Santos.
(Danghag lang??? hahaha)
9. RTC declared that as indicated in the Certificate of Marriage, “her marriage was celebrated without a need for a
marriage license in accordance of Article 34 of the Family Code, which is an admission that she cohabited with
Santos long before the celebration of their marriage
10. RTC find Santiago GUILTY of bigamy beyond reasonable doubt. (Tagam! hahaha)
11. Santiago filed a motion for reconsideration and contended that her marriage was void ab initio for not
complying with the requirement of Article 34 of the Family Code which is the five-year cohabitation period prior
to their marriage. (take note: she and Santos filed an affidavit of cohabitation before the celebration of their
marriage stating that they have cohabited for 5 years. Hahaha laban o bawi lang ng statement?)
12. The Court of Appeals stated that the petitioner’s claim was a vain attempt to put the validity of her marriage to
Santos in question thus affirming the RTC’s decision.

ISSUE:

1. Whether or not the CA erred in its decision charging the petitioner of bigamy despite her claim that her
marriage with Santos was void ab initio

HELD:

1. NO. SC stated that it would be absurdity to allow the petitioner to use her illegal action to escape criminal
conviction. (that her marriage with Santos was null because of lack of marriage license, but as clarified earlier,
they have falsified their certificate of marriage stating that they have cohabited for 5 years but when in fact they
haven’t). SC further added that it could not lend its aid to one who has consciously and voluntarily become a
party to an illegal act upon which the cause of action is founded.

The SC concurred with the RTC’s decision, which was affirmed by CA, however the SC disagreed with RTC’s
imposition of the principal penalty on her. She should not be charged as principal to the crime but only as an
accomplice.