Title
Manuel vs. People
Case Decision Date
G.R. No. 165842 Nov 29, 2005
Eduardo married Tina while still legally wed to Rubylus, claiming ignorance
of legal requirements. Convicted of bigamy, he was sentenced to prison and
ordered to pay Tina moral damages for deceit and emotional harm.
Jur.ph - Case Digest (G.R. No. 165842)
Advanced Research
Facts:
First Marriage
On July 28, 1975, Eduardo P. Manuel married Rubylus GaAa in Makati, which
was then part of Rizal Province. The marriage was solemnized by Msgr.
Feliciano Santos.
Second Marriage
In January 1996, Eduardo met Tina B. Gandalera in Dagupan City. Tina was a
21-year-old Computer Secretarial student, while Eduardo was 39. They
developed a relationship, and Eduardo proposed marriage, assuring Tina that
he was single. He even brought his parents to Baguio City to meet Tina’s
parents, who were also assured that Eduardo was single.
On April 22, 1996, Eduardo and Tina were married before Judge Antonio C.
Reyes of the RTC of Baguio City, Branch 61. Eduardo declared himself as
"single" in the marriage contract.
Marital Issues
The couple lived together for three years, during which they built a home in
Baguio City. However, starting in 1999, Eduardo began to distance himself,
visiting only twice or thrice a year. He also became abusive, slapping Tina
when she asked for financial support.
In January 2001, Eduardo left their home, took all his belongings, and ceased
providing financial support.
Discovery of Bigamy
In August 2001, Tina discovered Eduardo’s previous marriage to Rubylus GaAa
after obtaining a certified copy of their marriage contract from the National
Statistics Office (NSO). She felt humiliated and embarrassed upon learning that
Eduardo was already married when they wed.
Eduardo’s Defense
Eduardo testified that he informed Tina of his previous marriage, but she still
agreed to marry him. He claimed that he believed his first marriage was invalid
because Rubylus had been absent for over 20 years and had threatened suicide
if he did not marry her. He also stated that he did not know he needed a judicial
declaration to nullify his first marriage.
Issue:
1. Whether Eduardo P. Manuel is guilty of bigamy under Article 349 of the
Revised Penal Code.
2. Whether Eduardo’s belief that his first marriage was invalid due to his wife’s
20-year absence constitutes a valid defense.
3. Whether the award of P200,000.00 as moral damages to Tina Gandalera is
justified.
Ruling:
The Regional Trial Court (RTC) found Eduardo guilty of bigamy and sentenced
him to an indeterminate penalty of six (6) years and ten (10) months to ten (10)
years of imprisonment. He was also ordered to pay Tina P200,000.00 in moral
damages.
The Court of Appeals (CA) affirmed the RTC’s decision but modified the penalty
to two (2) years, four (4) months, and one (1) day of prision correccional as
minimum, to ten (10) years of prision mayor as maximum.
The Supreme Court denied Eduardo’s petition, affirming the CA’s decision. The
Court held that Eduardo’s belief in the invalidity of his first marriage did not
absolve him of liability for bigamy. The Court also upheld the award of moral
damages to Tina.
Ratio:
1. Elements of Bigamy: Under Article 349 of the Revised Penal Code, bigamy
requires: (a) a valid first marriage, (b) a second marriage contracted before the
first marriage is legally dissolved, and (c) the accused’s knowledge of the first
marriage. The prosecution proved all these elements beyond reasonable doubt.
2. Presumption of Death: Eduardo’s claim that his first wife was presumed dead
after 20 years of absence was rejected. Article 41 of the Family Code requires a
judicial declaration of presumptive death before a subsequent marriage can be
validly contracted. Eduardo failed to obtain such a declaration.
3. Good Faith Defense: Eduardo’s defense of good faith was unavailing. Even if he
believed his first marriage was invalid, his failure to secure a judicial
declaration of nullity or presumptive death rendered his second marriage
bigamous.
4. Moral Damages: The award of P200,000.00 in moral damages to Tina was
justified. She was an innocent victim of Eduardo’s deceit, suffering humiliation
and emotional distress due to his fraudulent actions.
Conclusion:
The Supreme Court upheld Eduardo’s conviction for bigamy, emphasizing the
importance of judicial processes in determining the validity of marriages. The
Court also affirmed the award of moral damages to Tina, recognizing the emotional
harm caused by Eduardo’s actions.
