Marriage through deception

Marissa was a 43-year-old widow with two children. After her husband passed away, she and her children lived with her in-laws in the province, where she helped manage the family’s piggery business. During this period, she met Daniel, a sales agent who regularly supplied piglets to the farm. As their meetings became more frequent, the two developed a close relationship, and Daniel often visited Marissa at home.

From the beginning, however, Marissa’s children, along with her brother-in-law and parents-in-law, were wary of Daniel. Despite their concerns, Daniel continued to pursue Marissa, and eventually they decided to get married. This decision remained unchanged even after Marissa met Grace, a woman who introduced herself as Daniel’s lawful wife of 20 years, a few months before the planned wedding.

The revelation did not discourage Marissa from proceeding with the marriage, she still married Daniel less than four years after they first met.

The marriage was solemnized by an authorized officer without a marriage license because Marissa and Daniel falsely represented that they had been living together as husband and wife for at least five years.

However, only four months after the wedding, Marissa and Daniel were charged with bigamy before the Regional Trial Court (RTC) upon the complaint of Grace. Daniel fled and went into hiding, leaving Marissa as the only accused to face the charges. She entered a plea of not guilty.

During the trial, Grace testified that she had met Marissa twice before the marriage and had clearly identified herself as Daniel’s legal wife.

Marissa denied this claim and maintained that she only learned of Grace’s existence after her marriage to Daniel.

Marissa further argued that her marriage to Daniel was void because they had no marriage license. Despite her defense, the RTC found Marissa guilty.

Consequently, Marissa was sentenced to imprisonment ranging from six months and one day as the minimum penalty to six years and one day as the maximum penalty.

Marissa appealed the decision before the Court of Appeals. She insisted that she could not be held liable for bigamy because her marriage to Daniel was void for lack of a marriage license.

Was Marissa correct? No.

Even if it was true that Marissa and Daniel had known each other for less than four years, the evidence showed that they deliberately misrepresented that they had cohabited as husband and wife for at least five years before marriage.

The situation was anomalous because Marissa sought to avoid criminal liability for bigamy by relying on her own unlawful acts.

In this case, Marissa may be held liable because she knew of Daniel’s existing and valid marriage. However, her liability is that of an accomplice rather than a principal offender. Therefore, the proper penalty should range from a minimum of six months to a maximum of four years of imprisonment, together with the accessory penalties prescribed by law. (Santiago vs. People, G.R. 200233, July 15, 2015)