G.R. No. 9754 ; September 29, 1914
THE UNITED STATES, plaintiff-appellee, vs. LEANDRO DE VERA, defendant-appellant.

FACTS:
Leandro de Vera was charged with the crime of illegal marriage (bigamy) for contracting a second marriage with Guadalupe Samarita on June 21, 1913, in Gasan, Tayabas, while his prior marriage to Modesta Lamadrid remained legally undissolved. The prosecution presented evidence, including a certified copy (Exhibit A) of an entry in the marriage register of the parish of Indan, Ambos Camarines, showing that De Vera married Lamadrid on January 7, 1907. The entry was authenticated by Father Salomon Balani, the parish priest and custodian of the register. De Vera denied the first marriage, claiming his first wife was Ana Lirag (who died in 1904) and that he only cohabited with Lamadrid. The trial court convicted De Vera and sentenced him to eight years and one day of prision mayor, with accessory penalties.

ISSUE:
Whether the trial court erred in admitting the parish marriage register entry as evidence of De Vera’s first marriage to Modesta Lamadrid, and whether such marriage was sufficiently proven to establish the crime of illegal marriage.

RULING:
The Supreme Court affirmed the conviction. The Court held that the entry in the parish marriage register was admissible as evidence of the first marriage. While the Municipal Code and General Orders required civil registration of marriages, they did not invalidate ecclesiastical records or preclude their use as evidence when civil certificates were unavailable. The register, kept by the parish priest as a representative of the Roman Catholic Church (a juridical entity), was a public record made in the regular course of duty. Father Balani, as the current custodian, properly authenticated the entry. The Court found the evidence conclusive: the register entry, coupled with De Vera’s own admission of cohabiting with Lamadrid and the identity of his parents in both marriage records, proved the first marriage. De Vera’s claim of being a widower when he married Samarita was false, as Lamadrid was still alive. Thus, De Vera was guilty of illegal marriage under Article 471 of the Penal Code. The penalty imposed by the trial court was proper.