PEOPLE vs. SANGALANG (74 OG 5977)

FACTS: The Sangalang spouses together with Gloria and Bienvenido were charged of the crime of simulation of birth. The information alleged that a child was furnished by Gloria to the Sangalangs. Accused Bienvenido registered the birth of said child in the local civil registrar by supplying to said office the necessary information required so that a birth certificate would be issued. He named the Sangalangs as the child’s parents. A birth certificate was hence issued. Information did not contain any specific allegation as to what the spouses did, except that they had conspired with Gloria and Bienvenido.

ISSUE: Whether the act of registration is a requirement to commit the crime of simulation of birth

HELD: In the crime of simulation of births, it must be shown that the “pretending parents” have registered or caused in the registration of the child as their own with the Registry of Births, or that in doing so they were motivated by a desire to cause the loss of any trace as to the child’s true filiation to his prejudice. In the instant case, SC found no evidence to support the finding of Trial Court that the registration was effected by the Sangalangs.

PEOPLE vs. ARAGON (100 PHIL 103)

FACTS: Proceso Rosima contracted marriage with Gorrea. While his marriage with the latter subsist, he contracted a canonical marriage with Faicol. Gorrea is staying in Cebu while Faicol is in Iloilo. He was a traveling salesman thus, he commuted between Iloilo and Cebu. When Gorrea died, he brought Faicol to Cebu where the latter worked as teacher-nurse. She later on suffered injuries in her eyes caused by physical maltreatment of Rosima and was sent to Iloilo to undergo treatment. While she was in Iloilo, Rosima contracted a third marriage with Maglasang. CFI found him guilty of bigamy.

ISSUE: Whether the third marriage is null and void

HELD: A subsequent marriage contracted by any person during the lifetime of his first spouse is illegal and void from its performance, and no judicial decree is necessary to establish its invalidity, as distinguished from mere annullable marriages. The action was instituted upon the complaint of the second wife whose marriage with Rosima was not renewed after the death of the first wife and before the third marriage was entered into. Hence, the last marriage was a valid one and prosecution against Rosima for contracting marriage cannot prosper.