G.R. No. L-8502; October 10, 1913
THE UNITED STATES, plaintiff-appellee, vs. DOMINGO SAN JUAN, defendant-appellant.

Domingo San Juan, a minister of the National Evangelical Church of the Philippines, performed a marriage ceremony between Florencio San Miguel and Eulogia Dizon. Eulogia Dizon was under the age of eighteen at the time, and the marriage was solemnized without the prior consent of her father, Esteban Dizon. An information was filed against the spouses, the two witnesses, and the minister. The prosecution dismissed the case against the spouses and one witness after the father subsequently gave his consent to the marriage, and against the other witness so he could testify for the government. Only the minister, Domingo San Juan, remained as the defendant. He was convicted by the Court of First Instance of Manila for violating Article 479 of the Penal Code in relation to General Orders No. 68, as amended, and was sentenced to suspension from his profession for four years, a fine of 1,500 pesetas, and costs.

Whether Domingo San Juan is criminally liable for solemnizing a marriage where one contracting party was underage without prior parental consent, given that he allegedly acted in good faith and conducted an investigation into the ages, and that the parent subsequently gave consent.

No. The judgment of conviction is reversed and Domingo San Juan is acquitted. The Court found that the accused acted in good faith and without criminal intent. He conducted an investigation as required by law by obtaining sworn written statements from the contracting parties and witnesses attesting to the bride’s age. The testimony of the prosecution witnesses, who were released from liability to testify, was viewed with suspicion and was contradicted by their prior sworn written statements prepared at the time of the marriage. The Court applied the principle that crime generally requires criminal intent (dolo), and a mistake of fact in good faith negates such intent. The Court cited the precedent in United States v. Peñalosa, which held that a person who marries relying in good faith on a representation of age is not criminally responsible. The Court did not find it necessary to decide whether the marriage was “prohibited by law” under Article 479 or whether the father’s subsequent consent retroactively validated the marriage, as the acquittal was firmly based on the absence of criminal intent.