SC Acquits Woman Of Bigamy, Redefines Void Marriage Defense

SC Acquits Woman Of Bigamy, Redefines Void Marriage Defense

By Bing Jabadan – TheNATIONWEEK.com | August 19, 2026

MANILA, Philippines – In a powerful, precedent-setting decision, the Supreme Court has acquitted a woman of bigamy, clarifying that a marriage void from its inception can be used as a defense without a prior judicial declaration of nullity. This ruling, penned by Associate Justice Alfredo Benjamin S. Caguioa, fundamentally redefines the legal landscape surrounding bigamy prosecutions.

The High Court’s Third Division overturned the convictions handed down by both the Regional Trial Court of Pampanga and the Court of Appeals against Ma. Fe Imelda Lapira. Lapira faced bigamy charges under Article 349 of the Revised Penal Code for marrying Jimmy Fariscal while still legally bound, as evidenced by a marriage certificate, to Japanese national Takahiko Sato.

Lapira’s defense centered on the nullity of her first marriage to Sato, asserting that it was void ab initio due to the absence of a ceremony and a critical marriage license—both indispensable for validity. The Local Civil Registrar confirmed that no record existed of any marriage license application for Lapira and Sato.

Despite this compelling evidence, lower courts previously convicted Lapira, adhering to the principle that a prior judicial declaration of nullity was necessary before a second marriage could be contracted without criminal liability.

The Supreme Court, however, disagreed.

Citing its own Pulido v. People precedent, the Court underscored that a defendant in a bigamy case has the inherent right to challenge the validity of a prior marriage as a defense, even without a pre-existing court declaration. The Court articulated that a fundamental element of bigamy is the existence of a valid prior marriage. If this initial union was legally void from its inception, then that foundational element of the crime is inherently absent.

In Lapira’s case, the certified document from the Local Civil Registrar, unequivocally stating the absence of a marriage license for Lapira and Sato, dismantled the presumption of validity afforded to the marriage certificate.

Given the prosecution’s failure to present any further evidence substantiating the validity of the first marriage, the Supreme Court found the essential elements of bigamy shrouded in reasonable doubt, mandating Lapira’s acquittal.

This landmark decision, amplifying due process and the integrity of marital law, signals a significant shift in the interpretation and application of bigamy statutes, reinforcing that a genuinely void marriage cannot form the basis of a criminal conviction.

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