Santiago vs. People, G.R. No.

200233, July 15, 2015

FACTS: Estela Galang, the first wife of Nicanor Santiago filed a case of bigamy ag Leonila
Santiago & Nicanor Santiago. Leonila averred that their marriage was void due to lack of
marriage license. Hence, she shld not be charged w/bigamy.
ISSUE:
1) WON the marriage between Leonila & Nicanor is valid.
2) WON Santos and Santiago are guilty of bigamy.
HELD: (1)NO. Their marriage is not valid because of the subsisting marriage between
Galang & Nicanor.
HELD: (2) Yes. Santos contended her marriage with Santos was void for having been
secured without a marriage license. But they themselves perpetrated a false Certificate of
Marriage by misrepresenting that they were exempted from the license requirement based
on their fabricated claim that they had already cohabited as husband and wife for at least
five years prior their marriage.
In violation of our law against illegal marriages, Santiago married Santos while
knowing full well that they had not yet complied with the five-year cohabitation
requirement under Article 34 of the Family Code.
Santos is guilty of the crime of bigamy as an accomplice because of her knowledge of
the existing marriage of the prior marriage w/c constitutes an indispensable cooperation in
the commission of bigamy.