Eduardo P. Manuel v. People

Summary

Eduardo P. Manuel was convicted of bigamy for marrying Tina Gandalera in 1996 while still legally married to Rubylus Gaña since 1975. Eduardo argued good faith, claiming he believed his first wife was presumptively dead after 20 years of absence under Article 390 of the Civil Code. The Supreme Court affirmed his conviction, ruling that Article 41 of the Family Code requires a judicial declaration of presumptive death before remarriage to avoid bigamy liability. The Court rejected his good faith defense, emphasizing that the judicial declaration requirement protects both the present spouse from criminal prosecution and the State's interest in preserving marriage as a social institution. The Court also upheld the P200,000 moral damages award, finding that Eduardo's fraudulent misrepresentations caused willful injury to the private complainant under the abuse of rights doctrine in Articles 19, 20, and 21 of the Civil Code.