People v. Mata
REITERATIONFacts
The Antecedents: The defendants, Jacinta Mata and Quiterio Sarmiento, were convicted of adultery by the trial court. The evidence established a marriage ceremony between Jacinta Mata and the complaining witness, Marcial Tañedo Tiu Chiu, and carnal relations between Jacinta Mata and Quiterio Sarmiento. Procedural History: The trial court convicted the defendants of adultery. The Petition: The defendants appealed, contending that their marriage was bigamous, and therefore, their carnal relations should not constitute adultery.
Issue(s)
Whether the carnal relations between the defendants constitute adultery despite the alleged bigamous nature of the marriage between the complaining witness and Jacinta Mata. Whether General Orders No. 68 abrogated the provisions of the Penal Code penalizing adultery in cases of bigamous marriages.
Ruling
The judgment of the trial court convicting the defendants of the crime of adultery is affirmed. The carnal relations between the defendants constitute adultery, and General Orders No. 68 did not abrogate the relevant provisions of the Penal Code.
Ratio Decidendi
On whether the carnal relations constitute adultery despite the alleged bigamous nature of the marriage: The Court affirmed the conviction for adultery. Article 433 of the Penal Code defines adultery as committed by a married woman who lies with a man not her husband, and by him who lies with her knowing that she is married, 'although the marriage be afterwards declared void.' The Court emphasized that the lawmakers intended to penalize the infidelity of a married woman even if she is entitled to have her marriage contract declared null and void, until a formal judicial declaration of nullity is secured. This is because, until such a declaration, the marriage bond is considered to exist, and the offense against the vows taken and the family exists. The Court cited Groizard's commentary, stating that until a marriage is declared null by competent authority in a final judgment, the offense to the vows taken and the attack on the family exist, thus reuniting the essential conditions for punishment. The Court also referred to Law 81 of Toro, which did not allow allegations of nullity as an excuse for adulterers. On whether General Orders No. 68 abrogated the provisions of the Penal Code penalizing adultery in cases of bigamous marriages: The Court held that General Orders No. 68 did not abrogate the provisions of the Penal Code. While Section III of General Orders No. 68 declared subsequent marriages contracted during the life of a former spouse as illegal and void from the beginning, the Court opined that this order was not intended to abrogate the provisions of Spanish law that secured certain rights to the innocent party in a bigamous marriage, legitimized offspring, and recognized their right of inheritance. The Court reasoned that the gist of adultery is the danger of introducing spurious heirs, which is equally present in the infidelity of a wife in a bigamous marriage as in a lawful marriage. Therefore, the incontinence of the wife of a bigamous marriage, as long as the bigamous relations exist, was deemed by the Spanish legislator to constitute the crime of adultery. The Court concluded that a statute declaring bigamous marriages void should not be held to repeal by implication the provisions of the Penal Code penalizing as adulterous the incontinence of the wife of a bigamous marriage, unless it also repeals the statutes legitimizing the offspring of bigamous marriages, which was not the effect of General Orders No. 68.
Main Doctrine
The infidelity of a married woman, even if her marriage is bigamous and potentially voidable, constitutes the crime of adultery until a formal judicial decree of nullity is obtained. General Orders No. 68 did not abrogate this provision of the Penal Code.