GR L 2233; (April, 1906) (Digest)
G.R. No. L-2233: THE UNITED STATES, plaintiff-appellee, vs. AMBROSIO MINA, defendant-appellant.
FACTS:
Ambrosio Mina was charged with violating Article 479 of the Penal Code for celebrating a marriage prohibited by law. The information alleged that on or about August 3, 1904, in Narvacan, Ilocos Sur, Mina, being an ecclesiastical authority with the right to celebrate marriages, solemnized the marriage between Aleja Supnet and Ignacio Santo. He allegedly knew this marriage was illegal because Supnet was still legally married to Domingo Javier, with the prior marriage never having been dissolved.
ISSUE:
Whether the prosecution proved beyond a reasonable doubt that Ambrosio Mina was an ecclesiastical or civil authority authorized to celebrate marriagesan essential element of the crime defined under Article 479 of the Penal Code.
RULING:
No. The Supreme Court reversed the conviction and acquitted the accused. The Court held that the prosecution failed to present any evidence proving that Mina was a priest, minister, or any other ecclesiastical or civil authority authorized to solemnize marriages at the time of the alleged offense. This fact was an essential allegation of the information, as the offense under Article 479 can only be committed by such an authorized person. The presumption of innocence requires the prosecution to prove every essential element of the crime beyond a reasonable doubt. Since this crucial element remained unproven, the accused must be acquitted. The judgment of the trial court was reversed, with costs de oficio, and the accused’s bond was ordered canceled.
