2 Aspa Sayson vs.

People

G.R. No. 214018

Facts:
 Sayson filed petition for review on certiorari to the decision of RTC of San Carlos
City.
 Melchor Aspa Sayson and Celia Bayking Leonor were convicted of bigamy punishable
under Article 349.
 They contracted a subsequent marriage without complying with the conditions set
forth under Presidential Decree No. 1083 which states "in case of a marriage between
a Muslim and a non-Muslim, solemnized not in accordance with Muslim law or this
Code, the [Family Code of the Philippines, or Executive Order No. 209, in lieu of the
Civil Code of the Philippines], shall apply.
 The Regional Trial Court, Branch 58, San Carlos City, Negros Occidental, issued a
decision on January 12, 2010, finding the petitioners guilty of bigamy.
 The Court of Appeals affirmed their conviction but modified the penalty imposed on
Melchor.

Issue:
 Whether the petitioners' conviction for bigamy should be upheld.

Ruling:
 The SC denied the petition and affirmed the decision of the CA.
Ratio:
 The Court based its decision on Article 13 (2) of Presidential Decree No. 1083.
 Therefore, even though Melchor was a Muslim at the time of his marriage to Celia, he
cannot claim exemption from liability for the crime of bigamy.
 The Court emphasized that all the elements of the crime of bigamy have been
sufficiently established, thus upholding the petitioners' conviction.
 However, the Court modified the penalty imposed on Melchor.
 He was sentenced to an indeterminate penalty of four (4) years and two (2) months of
prision correccional in its medium, as a minimum, and eight (8) years and one (1)
day of prision mayor in its medium, as a maximum.