18/08/2026
The has acquitted a woman of bigamy, ruling that a prior marriage that was void from the beginning (𝘷𝘰𝘪𝘥 𝘢𝘣 𝘪𝘯𝘪𝘵𝘪𝘰) may be raised as a defense even without a prior judicial declaration of nullity.
In a Decision penned by Associate Justice Alfredo Benjamin S. Caguioa, the SC’s Third Division reversed the ruling of the Regional Trial Court (RTC) Pampanga and the Court of Appeals (CA), which had found Ma. Fe Imelda Lapira guilty of bigamy.
Lapira faced a bigamy charge under Article 349 of the 𝘙𝘦𝘷𝘪𝘴𝘦𝘥 𝘗𝘦𝘯𝘢𝘭 𝘊𝘰𝘥𝘦 for marrying Jimmy Fariscal while still married to Takahiko Sato as evidenced by a marriage certificate from the Office of the Civil Registrar General.
During trial, Lapira argued that her marriage to Sato was void because no ceremony took place and no marriage license had been issued, both of which were required for validity. The Local Civil Registrar confirmed that there was no record of the application for a marriage license for Lapira and Sato.
In acquitting Lapira, the SC applied its ruling in the 2021 case of 𝘗𝘶𝘭𝘪𝘥𝘰 𝘷. 𝘗𝘦𝘰𝘱𝘭𝘦, which held that an accused in a bigamy case may directly argue that a previous marriage is void as a defense, even without a prior court declaration.
The SC explained that one of the essential elements of bigamy is the existence of a valid prior marriage. If the first marriage was void from the beginning, that element is absent.
In this case, the certification from the Local Civil Registrar sufficiently proved that no marriage license was issued to Lapira and Sato. This certification was enough to counter the presumption of the marriage certificate’s validity.
Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=171178.
Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=165698.
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