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2 Aspa Sayson Vs PPL
2 Aspa Sayson Vs PPL
People
Facts:
Sayson filed petition for review on certiorari to the decision of RTC of San Carlos
City.
Melchor Aspa Sayson and Celia Bayking Leonor were convicted of bigamy punishable
under Article 349.
They contracted a subsequent marriage without complying with the conditions set
forth under Presidential Decree No. 1083 which states "in case of a marriage between
a Muslim and a non-Muslim, solemnized not in accordance with Muslim law or this
Code, the [Family Code of the Philippines, or Executive Order No. 209, in lieu of the
Civil Code of the Philippines], shall apply.
The Regional Trial Court, Branch 58, San Carlos City, Negros Occidental, issued a
decision on January 12, 2010, finding the petitioners guilty of bigamy.
The Court of Appeals affirmed their conviction but modified the penalty imposed on
Melchor.
Issue:
Whether the petitioners' conviction for bigamy should be upheld.
Ruling:
The SC denied the petition and affirmed the decision of the CA.
Ratio:
The Court based its decision on Article 13 (2) of Presidential Decree No. 1083.
Therefore, even though Melchor was a Muslim at the time of his marriage to Celia, he
cannot claim exemption from liability for the crime of bigamy.
The Court emphasized that all the elements of the crime of bigamy have been
sufficiently established, thus upholding the petitioners' conviction.
However, the Court modified the penalty imposed on Melchor.
He was sentenced to an indeterminate penalty of four (4) years and two (2) months of
prision correccional in its medium, as a minimum, and eight (8) years and one (1)
day of prision mayor in its medium, as a maximum.