People v. Zamoranos
REITERATIONFacts
The Antecedents: Atty. Marietta D. Zamoranos (Zamoranos) married Jesus de Guzman (De Guzman) in Islamic rites on May 3, 1982, after converting to Islam. They remarried in civil rites on July 30, 1982. On December 18, 1983, they obtained a divorce by talaq, which was confirmed by a Decree of Divorce issued by the Shari'a Circuit Court on June 18, 1992. Zamoranos then married Samson R. Pacasum, Sr. (Pacasum) in Islamic rites on December 20, 1989, and in civil rites on December 28, 1992. They had three children. Their relationship soured, leading to a custody battle and a compromise agreement. Pacasum subsequently filed several cases against Zamoranos, including a Petition for Annulment of Marriage (later amended to Declaration of a Void Marriage) and a criminal complaint for Bigamy. Procedural History: Pacasum alleged that Zamoranos' marriage to him was void ab initio because her prior marriage to De Guzman was still subsisting. The RTC, Branch 2, Iligan City, dismissed Pacasum's petition for declaration of nullity of marriage for lack of jurisdiction, ruling that the Shari'a Circuit Court had exclusive jurisdiction over the matter as Zamoranos and De Guzman were Muslims whose marriage and divorce were governed by PD 1083. This decision was affirmed by the Court of Appeals (CA) and the Supreme Court. Meanwhile, an Information for Bigamy was filed against Zamoranos before the RTC, Branch 6, Iligan City. Zamoranos filed a Motion to Quash the Information, arguing lack of jurisdiction. The RTC, Branch 6, denied the motion. Zamoranos filed a petition for certiorari with the CA, which dismissed her petition, holding that the RTC's denial was not an act of grave abuse of discretion. Zamoranos and Pacasum filed separate petitions for review on certiorari before the Supreme Court. The Petition: Zamoranos argued that the CA erred in upholding the RTC's denial of her motion to quash, as the prior rulings establishing her Muslim status and the validity of her divorce from De Guzman under PD 1083 divested the RTC of jurisdiction over the Bigamy charge. Pacasum, conversely, argued that Zamoranos is not a Muslim and her prior marriage was not validly dissolved.
Issue(s)
Whether the Court of Appeals correctly dismissed Atty. Marietta D. Zamoranos' petition for certiorari. Whether the Regional Trial Court, Branch 6, Iligan City, has jurisdiction to try Atty. Marietta D. Zamoranos for Bigamy, considering the prior rulings on her Muslim status and the validity of her divorce by talaq.
Ruling
The petition in G.R. No. 193902 is GRANTED. The petition in G.R. No. 194075 is DENIED. The Decision of the Court of Appeals in CA-G.R. SP No. 03525-MIN is REVERSED and SET ASIDE. Accordingly, the Motion to Quash the Information in Criminal Case No. 06-12305 for Bigamy is GRANTED.
Ratio Decidendi
On the propriety of certiorari: The Court reiterated that while a denial of a motion to quash is generally an interlocutory order not subject to appeal, certiorari is an appropriate remedy in exceptional cases, such as when the denial constitutes an error of jurisdiction or grave abuse of discretion. The Court found that the RTC, Branch 6, Iligan City, committed an error of jurisdiction in denying Zamoranos' motion to quash, thus justifying the resort to certiorari. The CA's dismissal of the petition for certiorari was therefore reversed. On the jurisdiction of the RTC over the Bigamy charge: The Supreme Court held that the RTC, Branch 6, Iligan City, committed an error of jurisdiction in denying Zamoranos' motion to quash. The Court emphasized that the prior final and executory decision of RTC, Branch 2, Iligan City, in Civil Case No. 6249, which was affirmed by the CA and the Supreme Court, had already declared that Zamoranos and De Guzman were Muslims, their marriage and divorce by talaq were governed by PD 1083, and that the Shari'a Circuit Court had exclusive jurisdiction over such matters. While the Shari'a Circuit Court does not have jurisdiction over offenses penalized under the Revised Penal Code (RPC), the charge of Bigamy in this case hinged on the validity of Zamoranos' prior marriage and its dissolution, which were matters exclusively within the domain of Muslim Personal Laws and the Shari'a courts. The Court noted that the RTC, Branch 6, should have taken cognizance of the categorical declaration of Zamoranos' Muslim status and the valid dissolution of her first marriage. The Court also considered the evidence presented by Zamoranos, including affidavits from an Ustadz and former court officials, confirming her Muslim status and the validity of her divorce by talaq. Therefore, the RTC, Branch 6, was without jurisdiction to try Zamoranos for Bigamy, as the subject matter of the offense was intrinsically tied to matters governed by PD 1083.
Main Doctrine
A criminal charge for Bigamy under the Revised Penal Code cannot be sustained if the accused's prior marriage, which is the basis for the charge, was contracted under the Code of Muslim Personal Laws (PD 1083) and was subsequently dissolved by a valid divorce by talaq recognized under the same Code, as such matters fall under the exclusive jurisdiction of the Shari'a Circuit Court.