tenebro v ca_vitug & carpio

7/27/2019 Tenebro v CA_Vitug & Carpio

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SEPARATE OPINION>

VITUG, J.:

Veronico Tenebro has been charged with bigamy for contracting, while still being married to Hilda Villareyes, a

second marriage with private complainant Leticia Ancajas. Tenebro argues that since his second marriage with

Ancajas has ultimately been declared void ab initio on the ground of the latters psychological incapacity, he should

be acquitted for the crime of bigamy.

The offense of bigamy is committed when one contracts a second or subsequent marriage before the fo rmer

marriage has been legally dissolved, or before the absent spouse has been declared presumptively dead by means of

a judgment rendered in the proper proceedings. 1 Bigamy presupposes a valid prior marriage and a subsequent

marriage, contracted during the subsistence of the prior union, which would have been binding were it not for its

being bigamous.

Would the absolute nullity of either the first or the second marriage, prior to its judicial declaration as being void,constitute a valid defense in a criminal action for bigamy?

I believe that, except for a void marriage on account of the psychological incapacity of a party or both parties to the

marriage under Article 36 of the Family Code (as so hereinafter explained), the answer must be in the affirmative.

Void marriages are inexistent from the very beginning, and no judicial decree is required to establish their nullity.2 As

early as the case of People vs. Aragon3 this Court has underscored the fact that the Revised Penal Code itself does

not, unlike the rule then prevailing in Spain, require the judicial declaration of nullity of a prior void marriage before it

can be raised by way of a defense in a criminal case for bigamy. Had the law contemplated otherwise, said the Court,

an express provision to that effect would or should have been inserted in the law, (but that in) its absence, (the

courts) are bound by (the) rule of strict interpretation of penal statutes. In contrast to a voidable marriage which

legally exists until judicially annulled (and, therefore, not a defense in a bigamy charge if the second marriage were

contracted prior to the decree of annulment) 4 the complete nullity, however, of a previously contracted marriage,

being void ab initio and legally inexistent, can outrightly be defense in an indictment of bigamy.

It has been held that, by virtue of Article 40 of the Family Code, a person may be convicted of bigamy although the

first marriage is ultimately adjudged void ab initio if, at the time the second marriage is contracted, there has as yet

no judicial declaration of nullity of the prior marriage.5 I maintain strong reservations to this ruling. Article 40 of the

Family Code reads:

Article 40. The absolute nullity of the previous marriage may be invoked for purposes of remarriage on the basis

solely of the final judgment declaring such previous marriage void.

It is only for purpose of remarriage that the law has expressed that the absolute nullity of the previous marriage

may be invoked on the basis solely of the final judgment declaring such previous marriage void. It may not be

amiss to state that under the regime of the Civil Code of 1950, the Supreme Court, in Wiegel vs. Judge Sempio-

Diy,6 has held that a subsequent marriage of one of the spouses of a prior void marriage is itself (the subsequent

marriage) void if it were contracted before a judicial declaration of nullity of the previous marriage. Although this


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pronouncement has been abandoned in a later decision of the court in Yap vs. Court of Appeals, 7 the Family Code,

however has seen it fit to adopt the Wiegel rule but only for purpose of remarriage which is just to say that the

subsequent marriage shall itself be considered void. There is no clear indication to conclude that the Family Code has

amended or intended to amend the Revised penal Code or to abandon the settled and prevailing jurisprudence on

the matter.8

A void marriage under Article 36 of the Family Code is a class by itself. The provision has been from Canon law

primarily to reconcile the grounds for nullity of marriage under civil law with those of church laws. 9 The

psychological incapacity to comply with the essential marital obligations of the spouses is completely distinct from

other grounds for nullity which are confined to the essential or formal requisites of a marriage, such as lack of legal

capacity or disqualification of the contracting parties, want of consent, absence of a marriage license, or the like.

The effects of a marriage attended by psychological incapacity of a party or the parties thereto may be said to have

the earmarks of a voidable, more than a void, marriage, remaining to be valid until it is judicially decreed to be a

nullity. Thus, Article 54 of the Family Code considers children conceived or born of such a void marriage before its

judicial declaration of nullity to be legitimate similar to the rule on a voidable marriage. It is expected, even as Ibelieve it safe to assume, that the spouses rights and obligations, property regime and successional rights would

continue unaffected, as if it were a voidable marriage, unless and until the marriage is judicially declared void for

basically two reasons: First, psychological incapacity, a newly-added ground for the nullity of a marriage under the

Family Code, breaches neither the essential nor the formal requisites of a valid marriages; 10 and second, unlike the

other grounds for nullity of marriage (i.e., relationship, minority of the parties, lack of license, mistake in the identity

of the parties) which are capable of relatively easy demonstration, psychological incapacity, however, being a mental

state, may not so readily be as evident.11 It would have been logical for the Family Code to consider such a marriage

explicitly voidable rather than void if it were not for apparent attempt to make it closely coincide with the Canon

Law rules and nomenclature.

Indeed, a void marriage due to psychological incapacity appears to merely differ from a voidable marriage in that,

unlike the latter, it is not convalidated by either cohabitation or prescription. It might be recalled that prior to republic

Act No. 8533, further amending the Family Code, an action or defense of absolute nullity of marriage falling under

Article 36, celebrated before the effectivity of the Code, could prescribe in ten years following the effectivity of the

Family Code. The initial provision of the ten-year period of prescription seems to betray a real consciousness by the

framers that marriages falling under Article 36 are truly meant to be inexistent.

Considerations, both logical and practical, would point to the fact that a void marriage due to psychological

incapacity remains, for all intents and purposes, to be binding and efficacious until judicially declared otherwise.

Without such marriage having first been declared a nullity (or otherwise dissolved), a subsequent marriage could

constitute bigamy. Thus, a civil case questioning the validity of the first marriage would not be a prejudicial issue

much in the same way that a civil case assailing a prior voidable mar riage (being valid until annulled) would not be

a prejudicial question to the prosecution of a criminal offense for bigamy.

In cases where the second marriage is void on grounds other than the existence of the first marriage, this Court has

declared in a line of cases that no crime of bigamy is committed.12 The Court has explained that for a person to be

held guilty of bigamy, it must, even as it needs only, be shown that the subsequent marriage has all the essential


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elements of a valid marriage, were it not for the subsisting first union. Hence, where it is established that the second

marriage has been contracted without the necessary license and thus void, 13 or that the accused is merely forced to

enter into the second (voidable) marriage, 14 no criminal liability for the crime of bigamy can attach. In both and like

instances, however, the lapses refers to the elements required for contracting a valid marriage. If, then, all the

requisites for the perfection of the contract marriage, freely and voluntarily entered into, are shown to be extant, the

criminal liability for bigamy can unassailably arise.

Since psychological incapacity, upon the other hand, does not relate to an infirmity in the elements,

either essential or formal, in contacting a valid marriage, the declaration of nullity subsequent to the

bigamous marriage due to that ground, without more, would be inconsequential in a criminal charge

for bigamy. The judicial declaration of nullity of a bigamous marriage on the ground of psychological incapacity

merely nullifies the effects of the marriage but it does not negate the fact ofperfection of the bigamous marriage.

Its subsequent declaration of nullity dissolves the relationship of the spouses but, being alien to the requisite

conditions for the perfection of the marriage, the judgment of the court is no defense on the part of the offender

who had entered into it.

Accordingly, I vote to dismiss the petition.

As Justice Carpio pointed out in his dissenting opinion in Tenebro:

1. The mere act of entering into a second marriage contract while the first marriagesubsists consummates the crime of bigamy, even if the second marriage were void abinitio on grounds other than the mere existence of the first marriage.[35]

2. A marriage declared by law void ab initio and judicially confirmed void from thebeginning, is deemed valid for the purpose of a criminal prosecution for bigamy.[36]

According to Justice Carpio, in so ruling, the majority opinion simply brushed aside the law andoverturned 75 years of consistent rulings that if the second marriage were void on grounds otherthan the existence of the first marriage, there is no crime of bigamy. Justice Carpio reminded that, Itis an essential element of the crime of bigamy that the alleged second marriage, having all theessential requisites, would be valid were it not for the subsistence of the first marriage.[37]

Article 41 of the Family Code, notArticle 40, should have been the basis for convicting Tenebro. Itshould be reiterated that Article 40 of the Family Code is merely a rule of procedure.[38] Itcontemplates a situation of two void marriages: a prior existing void marriage and a second marriagethat would have been valid had there not been a prior void marriage.

To illustrate Article 40 of the Family Code, the Supreme Court consistently cites the case of Wiegel

v. Sempio-Diy.[39]Here, Karl Wiegel sought the declaration of nullity of his marriage to Lilia Wiegel,which was celebrated in 1978, on the ground of Lilias previous existing marriage to a certainEduardo Maxion, which was celebrated in 1972. While admitting that her marriage to Maxionexisted, Lilia claimed it to be null and void because they were allegedly forced to enter the maritalunion. Contesting the validity of the pre-trial court order, Lilia asked that she be able to presentevidence before the court not only that the first marriage was vitiated by force, but also to prove thatMaxion was already married to somebody else at the time she married him. Judge Sempio-Diy didnot allow the presentation of evidence since the existence of force exerted on both parties of the firstmarriage had already been agreed upon at pre-trial. On a side note, the question also begs itself: is
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it really possible under Article 48 of the Family Code[40]and its predecessors to stipulate on theground for nullity of a marriage?

In upholding Sempio-Diys order, the Supreme Court held that, first, Lilia does not have to presentevidence that her first marriage has been vitiated by force. A marriage vitiated by force is merelyvoidablethat is, valid until annulled. Since no annulment had yet been made, it is clear that when

Lilia married Wiegel, she is still validly married to Maxion. Consequently, her marriage to Wiegel isvoid..Second, Lilia does not have to present evidence as to her husbands alleged marriage at thetime they married. While Lilia and Maxions marriage is void, it still needs to be declared void by acourt.[41] Thus, the Supreme Court said that since the first marriage had not been annulled ordeclared void, then Lilia was considered a married woman at the time she married Karl,consequently, her marriage with Karl is void. This is a proper application of Article 40, and the authoragrees to the various aforementioned conclusions. However, Wiegelis not a case involving bigamy.

It is shocking therefore that the Supreme Court ruled, without qualification, in Terre v. Terre[42]thatthe second marriage entered into by Atty. Jordan Terre was bigamous and criminal in nature. Inthis case, Dorothy Terre accused Atty. Jordan Terre of grossly immoral conduct for contracting asecond marriage and living with another woman, while his prior marriage with Dorothy remained

subsisting. It turned out that Dorothy had a previous marriage with one Merlito Bercenilla, her firstcousin. Jordan thus believed that his marriage to Dorothy was void ab initio, and that he couldcontract a second marriage with Helen Malicdem.

The Supreme Court disbarred Jordan for grossly immoral conduct under Rule 138, Sec. 27 of theRules of Court.[43]The Court held that even if Jordan had entered into his first marriage in goodfaith, a judicial declaration of the nullity of the same is still required before remarriage. The SupremeCourt then held his marriage to Dorothy was valid and his marriage to Helen was bigamous andcriminal in nature.

But, why was there a need to qualify Jordans second marriage as bigamous and criminal innature? Surely, for the criminal liability for bigamy to attach, both the first and second marriagesmust be valid?

Mercado[44] is yet another difficult ruling. Here, at the time of the celebration of the marriage ofVincent Mercado and Consuelo Tan, Mercado was already married to a certain Thelma Oliva.Consequently, Consuelo Tan filed a complaint for bigamy against Mercado. More than a month afterthe bigamy case was filed, Mercado filed an action for the declaration of nullity of his marriage toThelma Oliva with the RTC, which judicially declared the marriage between Mercado and Oliva to benull and void on the basis of Article 36 of the Family Code. Mercado was still convicted of bigamy bythe lower court and thus, appealed to the Supreme Court.

The Supreme Court ruled that Article 40 of the Family Code (again, a rule of procedure )[45]

effectively sets aside the conflicting jurisprudence on whether a judicial declaration of nullity ofmarriage is necessary before one can contract a subsequent marriage. The fact that the firstmarriage is void from the beginning cannot now be a defense against a bigamy charge . Aswith a voidable marriage, there must be a judicial declaration of the nullity of a marriage beforecontracting a second marriage.[46]That Mercado subsequently obtained a judicial declaration of thenullity of his first marriage was immaterial as the crime had already been consummated.

Another Supreme Court decision that has confused the application of the Article 40 of the FamilyCode is that of Marbella-Bobis v. Bobis.[47]In this case, Isagani Bobis first married a certain Dulce
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Javier in 1985. Without annulling, nullifying, or terminating his first marriage, Isagani married asecond time, to petitioner Imelda Marbella-Bobis in 1996. Then, Isagani married a third time, to oneJulia Hernandez. After an information for bigamy was filed against Isagani by Imelda, he initiated acivil action for the judicial declaration of absolute nullity of his first marriage on the ground that it hadbeen celebrated without a marriage license. He then moved to have the proceedings in the criminalcase suspended invoking the pending civil case for the nullity of his first marriage as a prejudicial

question.

The Supreme Court held that the subsequent filing of a civil action for declaration of nullity of aprevious marriage does not constitute a prejudicial question to a criminal case for bigamy. Article 40of the Family Code requires a prior judicial declaration of nullity of a previous marriage before a partymay remarry and that it is not for the parties, particularly the accused, to determine the validity orinvalidity of the marriage.[48]

Surely, reductio ad absurdum, if a person is married to a sibling, there is no need for a priordeclaration of nullity. The law itself tells us that the complete absence of a valid marriage licensemakes a marriage absolutely void.[49] Article 39 of the Family Code is very clear: The action ordefense for the declaration of absolute nullity of a marriage shall not prescribe.

While Isagani Bobis should not have married three times, should the Supreme Court really haveruled on passion against the adventurous bigamist? And which of the three marriages was actuallybigamous? Yes, the second marriage in Bobis is void. However, it cannot be considered bigamousthrough Article 40 of the Family Code. It is the third marriage that is void, illegal, and bigamousunder Article 41 of the Family Code.

Either Bobis is right and Morigo v. People[50]is wrong, or vice-versa.

In the case of Morigo, Lucio Morigo married Lucia Barrete, who then reported back to her work inCanada eight days after their marriage. A year later, Barrete filed a petition for divorce against

Morigo before the Ontario Court, which petition was granted. Morigo married Maria Lumbago andeventually filed a complaint for judicial declaration of nullity of his marriage to Barrete with the FamilyCourt on the ground that no marriage ceremony had taken place. Soon after, a charge of bigamywas filed against Morigo by Lumbago. Morigo moved for suspension of the arraignment on theground that the civil case for judicial nullification of his first marriage posed a prejudicial question inthe bigamy case. His motion was denied and he was convicted. While the case was on review in theCourt of Appeals, the Family Courtjudicially declared Morigos first marriage void for absence of amarriage ceremony. The Court of Appeals, however, affirmed the bigamy conviction on the groundthat the subsequent declaration of Morigo and Lucias marriage could not acquit Morigo as what issought to be punished by the Revised Penal Code is the act of contracting a second marriage beforethe first marriage has been dissolved.

The Supreme Court overturned Morigos conviction since the first element of bigamythat is, thatthe offender had been legally marriedwas not present. Morigo and Lucias marriage is void abinitio and as such, following the principle of retroactivity of a marriage being declared void ab initio,the two were never married from the beginning.

But was not Morigo still married when he married a second time? Did not the Supreme Court saythat a person cannot judge for himself whether his marriage is valid or not? And did not the SupremeCourt also tell us that the subsequent filing of a civil action for declaration of nullity of a previousmarriage does not constitute a prejudicial question to a criminal case for bigamy; that Article 40 of
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the Family Code requires a prior judicial declaration of nullity of a previous marriage before a partymay remarry; and that it is not for the parties, particularly the accused, to determine the validity orinvalidity of the marriage? And finally, unlike Isagani Bobis, both of Morigos marriages took placewhen the Family Code was already in effect, so why was Article 40 not applied?

Interestingly, the Supreme Court distinguished Morigo from Mercado in the Bobis case. The

Supreme Court said that in Mercado, while the judicial declaration of nullity of the first marriage waslikewise obtained after the second marriage was already celebrated,[51]unlike Morigo, the marriagein Mercado was celebrated on two occasions: Ostensibly, at least, the first marriage appeared tohave transpired, although later declared void ab initio.[52]

Please note, however: In Morigo, there was no marriage ceremony performed by a duly authorizedsolemnizing officer. In Mercado, the marriage was declared void on the basis of Article 36 of theFamily Codenot on the absence of either an essential or a formal requisite. The two cases shouldnot have been compared. Again, I raise the question: Is psychological incapacity an element of legalcapacity or of consent to enter into a marriage?

Based on the case of Morigo and present jurisprudence, is it safe to say that:

1. If one wanted to get out of a criminal conviction, the defense is not psychological incapacity orthe lack of a marriage license, but the lack of a marriage ceremony?

2. If both marriage ceremony and marriage license are elements of formal requisites, then theabsence of a marriage license does not have the same effect as the absence of a marriageceremony? [Please note: A marriage ceremony does not have a particular form, but a marriagelicense does.]

3. If the defense were psychological incapacity, it will not acquit one of bigamy? Therefore,psychological incapacity does not render a marriage void? Is the Supreme Court, therefore,ready to say that the presence of psychological incapacity merely makes a marriage voidable?If so, then Mercado is correct?

4. One will always be a bigamist even if both marriages were void and one did not seek the nullityof the first marriage before subsequently marrying?

5. No one can ever file a petition based on newly-discovered evidence and a void marriage canbe ratified on the basis of res judicata, specifically because of Mallion?

6. The existence of a judicial declaration of a void marriage is not a defense to bigamy if theground is any other than the absence of a marriage ceremony?
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tenebro v ca_vitug & carpio

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