People v. Isla
REITERATIONFacts
The Antecedents: The defendant, Felipe Isla, was prosecuted for bigamy. It was admitted that he married Aleja Pascual on November 14, 1901. The prosecution alleged that he had previously married Maria Hilario on November 5, 1899. Procedural History: The trial court found the defendant guilty. The Petition: The defendant appealed, claiming he was not the Felipe Isla who contracted the first marriage. He also questioned the applicable article of the Penal Code.
Issue(s)
Whether the defendant is the same Felipe Isla who contracted the marriage in 1899. Whether Article 440 or Article 471 of the Penal Code should apply to the offense.
Ruling
The judgment of the court below is confirmed. The defendant is guilty of bigamy under Article 471 of the Penal Code.
Ratio Decidendi
On whether the defendant is the same Felipe Isla who contracted the marriage in 1899: The Court found sufficient evidence to establish that the defendant was indeed the Felipe Isla who married Maria Hilario in 1899. This evidence included the testimony of Maria Hilario herself, who testified that the defendant was the person she married. Furthermore, the two witnesses to the 1899 marriage, Maximo Briseno and Alejandra de los Angeles, also testified that the defendant was the person they witnessed marry Maria Hilario. While the defendant claimed to be the son of Gabriel Isla and Petra de Leon, and the record of the first marriage indicated the groom was the son of Valentin Isla and Maria Mandayag, the Court considered the direct testimony of the witnesses and Maria Hilario as overriding the discrepancy in parentage. The Court noted that the statement regarding parentage in the marriage record was incorrect, but other evidence pointed to the identity of the Felipe Isla in question. On whether Article 440 or Article 471 of the Penal Code should apply: The Court held that Article 471 of the Penal Code was the applicable provision. The Court discussed the history and intent of Article 455 (later Article 440) of the Penal Code, which was introduced to address public scandal arising from canonical marriages contracted after the promulgation of the Civil Marriage Law, or vice versa, without legitimate annulment. However, the Court clarified that the law regarding civil marriages in 1870 was never promulgated or in force in the Philippines. Civil marriages were only recognized in the Philippines upon the promulgation of General Orders, No. 68, on December 11, 1899. In the present case, both marriages contracted by the defendant were canonical. Therefore, the offense fell squarely under Article 471, which punishes bigamy. The Court cited its previous application of Article 471 to a case where the second marriage was celebrated under General Orders, No. 68, indicating that the nature of the second marriage ceremony does not alter the applicability of the bigamy provision when the first marriage was canonical and subsisting.
Main Doctrine
A person who contracts a second canonical marriage while a prior canonical marriage is subsisting, without the prior marriage being legitimately annulled, is guilty of bigamy under Article 471 of the Penal Code, even if the second marriage was celebrated under General Orders No. 68.