Tenebro v. Court of Appeals

Summary

This landmark Supreme Court case resolved the novel issue of whether subsequent judicial declaration of marriage nullity on psychological incapacity grounds affects criminal liability for bigamy. Veronico Tenebro contracted multiple marriages: first to Hilda Villareyes (1986), second to Leticia Ancajas (1990), and third to Nilda Villegas (1993). When prosecuted for bigamy by Ancajas, Tenebro defended by claiming the first marriage was invalid and that the subsequent nullity declaration of his second marriage retroacted to eliminate criminal liability. The Supreme Court unanimously rejected this defense, establishing that criminal liability for bigamy is determined at the time the second marriage is contracted, not by subsequent civil declarations. The Court emphasized that the crime is consummated upon celebrating the second marriage during subsistence of a valid first marriage, regardless of later nullity declarations. This decision protects the sanctity of marriage while preventing circumvention of criminal liability through subsequent civil proceedings. The conviction was upheld with the prescribed penalty under the Indeterminate Sentence Law.