Vitangcol vs People

Facts:
P was charged bigamy. He was arraigned, but he pleaded not guilty.
Trial then ensued.
o Prosecution: P married Alice Eduardo at the Manila Cathedral in
Intramuros. After some time, Ps wife began hearing rumors that
P was previously married to a certain Gina Gaerlan, as evidenced
by a marriage contract registered with the NSO. Alice then filed a
bigamy complaint against P.
P, on the other hand, alleged that before finalizing their marriage
plans, he revealed to Alice that he had a fake marriage with his college
girlfriend, a certain Gina Gaerlan. Nevertheless, Alice convinced him
that they proceed with the wedding.
P heard rumors from their household workers that Alice was having an
affair with a married man, which he confirmed later on. P then sought
the advice of his business lawyer who later on convinced Alice to end
the affair; the lawyer also warned Alice of any possible criminal liability.
Alice, allegedly in retaliation to the threat of criminal action against
her, filed a bigamy case against Norberto.
RTC: P is guilty beyond reasonable doubt of the crime of bigamy
CA: affirmed RTC decision, but modified the penalty
P filed for MR; CA denied MR; P filed before the SC
Issue:
W/N P is liable for bigamy
H/R:
Yes. Although P argues that there was no proof of existence of an
essential requisite of marriage the marriage license, the Court stated
that marriages are not dissolved through mere certifications by the
civil registrar.
o Four elements of bigamy:
Offender has been legally married
First marriage has not been legally dissolved, or spouse
could not yet be presumed dead
Contraction of a second marriage
Second marriage has all the requisites for validity
His first marriage was solemnized before the effectivity of the Family
Code; the marriage was then governed by the provisions of the Civil
Code.
Even though P presented a Certification from the Office of the Civil
Registrar of Imus which stated that after a diligent search, no record
could be found, it does not categorically state that ML 8683519 does
not exist.

o Castro case: no suspicion and no bigamy case involved

o Vitangcol: suspicion + bigamy case
P admitted the authenticity of his signature appearing on the marriage
contract between him and Gina. The marriage contract is a positive
piece of evidence as to the existence of Ps first marriage.
Second element is present: first marriage was not judicially declared
void.
Third element is present: P admitted to marrying Alice.
Fourth element: it is presumed that the subsequent marriage has all
the essential requisites.

Ruling:
Petition denied.
Cercado-Siga vs Cercado
Facts:
P claimed that they are the legitimate children of the late Vicente and
Benita Castillo, who were married in Rizal. P alleged that during the
lifetime of their parents, their father acquired a parcel of land. P further
claimed that upon the death of their father and by virtue of intestate
succession, ownership of the subject land pertained to them as heirs;
that upon the death of their mother, her share was acquired by P by
operation of law.
P read from a newspaper a notice that the estate of Vicente and a
certain Leonora Ditablan has been extrajudicially settled by their heirs,
R. Upon verification, P were furnished a copy of the Extrajudicial
Settlement of the Estate (deed) executed and signed by R.
o P insist that Vicente are not married; if so, then married is null
and void.
P presented the following documents:
o Contarto Matrimonial or the marriage contract
o Certification issued by Iglesia Filipina Independiente of its
acceptance of original marriage contract.
o Certification of non-production of record of birth of Simplicia