People v. Enriquez
REITERATIONFacts
The Antecedents: Dionisio Enriquez was married to Juliana Marcelo on July 21, 1886. In 1895, he left his wife and children and went to Laguna. Upon returning to Orion, Bataan, in 1901, he could not find his wife nor obtain any information about her whereabouts despite diligent search. Believing her dead, he contracted a second marriage with Joaquina Trajano on February 1, 1905. His first wife, Juliana Marcelo, reappeared in 1913, stating she had been absent from 1895 to 1913 and had no news of her husband during that period. Procedural History: The Court of First Instance of Bataan rendered a judgment on September 30, 1914, sentencing Dionisio Enriquez to six years and one day of prision mayor for the crime of illegal marriage. The defendant appealed this judgment. The Appeal: The defendant-appellant argued that he should not be held guilty of illegal marriage because, at the time of contracting the second marriage, he had a reasonable and well-founded belief that his first wife was dead, having had no news of her for nineteen years and having made diligent efforts to find her.
Issue(s)
Whether the accused is guilty of the crime of illegal marriage despite his belief that his first wife was dead. Whether the accused's belief in the death of his first wife was reasonable and well-founded.
Ruling
The Supreme Court reversed the judgment of the Court of First Instance, acquitting the defendant Dionisio Enriquez. The Court held that the accused did not possess the fraudulent intent necessary to constitute the crime of illegal marriage, as he acted on a reasonable and well-founded belief that his first wife was dead.
Ratio Decidendi
On Issue 1: The Supreme Court held that the accused is not guilty of illegal marriage because the essential element of fraudulent intent was absent. The Court recognized that the defendant contracted the second marriage under the honest and reasonable belief that his first wife, Juliana Marcelo, was dead. This belief was substantiated by the fact that he had not heard from her for nineteen years (from 1895 to 1913) and had made persistent and diligent efforts to locate her without success. The Court emphasized that without fraudulent intent, the crime of illegal marriage cannot be established. On Issue 2: The Court affirmed that the accused's belief in the death of his first wife was reasonable and well-founded. The nineteen-year period of no news, coupled with the defendant's unsuccessful attempts to find her, provided a sufficient basis for his belief. The Court also addressed the statement made by the defendant to the priest that he was single, explaining that this was satisfactorily accounted for and did not demonstrate bad faith, especially since his children and mother resided in the same municipality where the second marriage took place and the marriage was solemnized after due publication of banns. Therefore, the circumstances supported the reasonableness of his belief.
Main Doctrine
The Supreme Court reiterated that the crime of illegal marriage under Article 349 of the Revised Penal Code requires the element of fraudulent intent. This intent is negated if the accused contracted a subsequent marriage under the honest and reasonable belief that the former spouse was already dead, provided that such belief was founded upon diligent but fruitless efforts to ascertain the spouse's whereabouts and a considerable period of no news regarding the spouse. The Court found that the accused's nineteen-year absence of news from his first wife, coupled with his persistent search, justified his belief that she was dead, thus absolving him of the crime.