**Facts:**
This case involved Atilano O. Nollora, Jr. (“Nollora”) and Rowena P. Geraldino (“Geraldino”) being charged with bigamy on August 24, 2004, after Nollora, already married to Jesusa Pinat Nollora in 1999, contracted a second marriage with Geraldino in 2001. Nollora pleaded not guilty, while Geraldino also entered a similar plea. Both the prosecution and defense agreed upon the validity of Nollora’s first marriage, the occurrence of the second marriage, Nollora’s admission of the second marriage, Geraldino’s attached Certificate of Marriage, and Geraldino’s admittance of marriage. The primary issue revolved around the bigamous nature of the second marriage.
Nollora defended himself by claiming conversion to Islam before his first marriage, suggesting entitlement under his adopted faith to have multiple wives. Despite this, the trial court convicted Nollora while acquitting Geraldino due to insufficient evidence of her knowing complicity in the bigamy.
Nollora appealed to the Court of Appeals, which upheld the trial court’s decision. His further appeal to the Supreme Court centered on the contention that his second marriage did not constitute bigamy due to his claimed Muslim faith and the permissions it affords for polygamous marriages.
**Issues:**
1. Whether Nollora’s conversion to Islam exempts him from liability for bigamy.
2. Whether the evidence presented substantiates Nollora’s guilt for bigamy beyond reasonable doubt.
**Court’s Decision:**
The Philippine Supreme Court rejected Nollora’s defense and affirmed the appellate and trial court’s decisions. The Court clarified that bigamy applies irrespective of religious conversion, especially when the consequent marriage fails to adhere to the procedural and substantive requisites defined by the Code of Muslim Personal Laws. Thus, Nollora’s invocation of religious conversion did not exempt him from liability for bigamy, as his marriages were not solemnized under Islamic law but rather under Philippine civil laws. The Court concluded all elements of bigamy were satisfactorily proven – Nollora was legally married to Pinat; their marriage was not legally dissolved; Nollora admitted to marrying Geraldino; and this second marriage bore essential requisites for validity notwithstanding Nollora’s incapacity stemming from his prior marriage.
**Doctrine:**
The Court reiterated that the crime of bigamy does not accommodate exceptions based on religious conversion to Islam when the marriages in question are solemnized outside the auspices of Muslim law and do not comply with its requirements. It further emphasized that the legal consequences of a void marriage due to bigamy would stand, preventing individuals from deliberately contracting flawed marriages to evade penal laws.
**Class Notes:**
1. Bigamy (Art. 349, Revised Penal Code) requires the legal establishment of a subsequent marriage before the dissolution of or declaration of presumptivity of death of the first spouse.
2. Religious conversion does not inherently nullify obligations under civil law, especially if the subsequent marriage does not comply with the legal and ceremonial requisites of the adopted religion.
3. “Legal capacity” and “essential requisites for validity” form the cornerstone of valid marriages, under both civil law and, as relevant, the Code of Muslim Personal Laws.
4. The acquiescence in or awareness of a legal wrongdoing does not diminish its illegality, nor does it excuse one from consequences unless successfully disproven beyond a reasonable doubt.
**Historical Background:**
The case embodies the interplay between civil law and religious law in the Philippines, a predominantly Catholic country that also recognizes Islamic law among its Muslim population. The intersection arises in matters of personal law, such as marriage, where the State upholds civil standards unless explicitly devolved to religious laws. This legal tension underscores the complexities of multicultural nation-states navigating the coexistence of diverse legal and religious doctrines within a singular national legal framework.
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