Leonila Santiago v.

People of the PH
GR 200233      
July 15, 2015

Facts:
            4 months after solemnization of marriage, Leonila (petitioner) and
Nicanor Santiago were served an information for Bigamy for the prosecution
adduced that Nicaonor was still married to Estela when he entered into the
2ndmarriage; he was able to escape while petitioner pleaded ‘not guilty’
relying on the fact that when she married him, she thought he was single.
She soon averred that their marriage was void due to lack of marriage
license, wherein she should not then be charged with bigamy. 11 years after
inception if criminal case, Estela Galang, the first wife, testified for the
prosecution. She alleged that she had met petitioner and introduced herself
as the legal wife. Petitioner denied allegation and stated that she met Estela
only after she had already married Nicanor.

            Issue:   W/N petitioner is co-accused in the instant case of

Bigamy. 
                        W/N marriage between Leonila and Nicanor is valid
Held:

            Lower courts consistently found that petitioner indeed knew of the
first marriage as shown by the totality of the following circumstances: (1)
when Nicanor was courting and visiting petitioner in the house of her in-
laws, they openly showed their disapproval of him (2) it was incredible for a
learned person like petitioner to not know of his true civil status (3) Estela,
who was the more credible witness, compared to petitioner who had various
inconsistent testimonies, straightforwardly testified that she had already told
petitioner on two occasions that the former was the legal wife of Nicanor.
In People v. Archilla, knowledge of the second wife of the fact of her
spouse’s existing prior marriage, constitutes an indispensable cooperation in
the commission of Bigamy, which makes her responsible as an accomplice.
She is not co-accused. She is guilty of Bigamy as an accomplice thereby
sentenced to 6m arresto mayor to 4y prision correccional.