17/08/2026
The has acquitted a woman of bigamy, ruling that a prior marriage that was void from the beginning (๐ท๐ฐ๐ช๐ฅ ๐ข๐ฃ ๐ช๐ฏ๐ช๐ต๐ช๐ฐ) may be raised as a defense even without a prior judicial declaration of nullity.
In a Decision penned by Associate Justice Alfredo Benjamin S. Caguioa, the SCโs Third Division reversed the ruling of the Regional Trial Court (RTC) Pampanga and the Court of Appeals (CA), which had found Ma. Fe Imelda Lapira guilty of bigamy.
Lapira faced a bigamy charge under Article 349 of the ๐๐ฆ๐ท๐ช๐ด๐ฆ๐ฅ ๐๐ฆ๐ฏ๐ข๐ญ ๐๐ฐ๐ฅ๐ฆ for marrying Jimmy Fariscal while still married to Takahiko Sato as evidenced by a marriage certificate from the Office of the Civil Registrar General.
During trial, Lapira argued that her marriage to Sato was void because no ceremony took place and no marriage license had been issued, both of which were required for validity. The Local Civil Registrar confirmed that there was no record of the application for a marriage license for Lapira and Sato.
In acquitting Lapira, the SC applied its ruling in the 2021 case of ๐๐ถ๐ญ๐ช๐ฅ๐ฐ ๐ท. ๐๐ฆ๐ฐ๐ฑ๐ญ๐ฆ, which held that an accused in a bigamy case may directly argue that a previous marriage is void as a defense, even without a prior court declaration.
The SC explained that one of the essential elements of bigamy is the existence of a valid prior marriage. If the first marriage was void from the beginning, that element is absent.
In this case, the certification from the Local Civil Registrar sufficiently proved that no marriage license was issued to Lapira and Sato. This certification was enough to counter the presumption of the marriage certificateโs validity.
Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=171178.
Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=165698.
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