Imelda married Jimmy in Pampanga in 2001. Years later, Jimmy discovered that before marrying him, Imelda had allegedly married a Japanese national named Takahiko Sato in Bulacan in 2000. Because of this, Jimmy filed a criminal case for Bigamy against Imelda.

Imelda denied committing bigamy. She claimed that the supposed marriage with Takahiko was merely arranged to facilitate her entry into Japan for work. According to her, no real marriage ceremony took place. She alleged that she merely signed a blank sheet of paper in Makati City in the presence of acquaintances facilitating her travel documents, and that neither Takahiko nor the supposed solemnizing officer were present when she signed it. She likewise asserted that she never applied for a marriage license.

To support her claim, Imelda presented a certification from the Local Civil Registrar of Imus, Cavite stating that there was no record of any application for marriage license between her and Takahiko, and that the records for the year 2000 remained intact.

The trial court convicted Imelda of Bigamy. The Court of Appeals affirmed the conviction, ruling that even if the first marriage were void, Imelda could not invoke such invalidity absent a prior judicial declaration of nullity.

Was the conviction correct?

No. One of the essential elements of Bigamy is the existence of a prior valid marriage. If the supposed first marriage is void ab initio, then an essential element of the crime is absent.

The Supreme Court held that a judicial declaration of nullity is not necessary before an accused may invoke the void nature of a prior marriage as a defense in a criminal prosecution for Bigamy. A void marriage may be collaterally attacked in the criminal case itself.

In this case, Imelda sufficiently established that the alleged first marriage was void for lack of a marriage license. Under the Family Code, a marriage license is a formal requisite of marriage, and the absence thereof renders the marriage void ab initio. The certification issued by the Local Civil Registrar stating that no marriage license application existed between Imelda and Takahiko was sufficient evidence to rebut the presumption of regularity attached to the marriage certificate.

While the prosecution relied on the marriage certificate to prove the existence of the first marriage, the presumption in favor of the certificate was overturned by the certification from the civil registrar. Beyond the marriage certificate itself, the prosecution failed to present other competent proof establishing the validity of the alleged first marriage.

All these circumstances created reasonable doubt as to whether a valid prior marriage actually existed between Imelda and Takahiko. Since a valid first marriage is an indispensable element of Bigamy, Imelda could not be convicted.

Thus, the Supreme Court acquitted Imelda on the ground that the prosecution failed to prove all the elements of Bigamy beyond reasonable doubt.

Lapira v. People of the Philippines. G.R. No. 233512. February 26, 2026.