In Pulido v. People (G.R. No. 220149, 27 July 2021), the Supreme Court En Banc abandoned its earlier rulings that a judicial declaration of absolute nullity of the first, and/or second marriages cannot be raised as a defense by the accused in a criminal prosecution for bigamy.It was ruled thata judicial declaration of absolute nullity is not necessary to prove a void ab initio prior and subsequent marriages in a bigamy case. Consequently, a judicial declaration of absolute nullity of the first and/or second marriages presented by an accused in the prosecution for bigamy is a valid defense, irrespective of the time within which they are secured. The Supreme Court explained that when the first marriage is void ab initio, one of the essential elements of bigamy is absent, i.e. a prior valid marriage. There can be no crime when the very act which was penalized by the law, i.e. contracting another marriage during the subsistence of a prior legal or valid marriage, is not present. The existence and the validity of the first marriage being an essential element of the crime of bigamy, it is but logical that a conviction for said offense cannot be sustained where there is no first marriage to begin with.Thus, an accused in a bigamy case should be allowed to raise the defense of a prior void ab initio marriage through competent evidence other than the judicial decree of nullity. However, in Bonbon v. People (G.R. No. 272844, 24 February 2025), the Supreme Court clarified that although a void subsequent marriage is a valid defense in a criminal prosecution for bigamy even without a judicial declaration of nullity, nonetheless, the accused still cannot rely on mere allegations, but must present testimonial or documentary evidence to support the same. Here, the accused alleged that the second marriage was void due to the absence of a marriage ceremony. Other than bare allegations, he failed to offer other evidence to support his claims.

In Bonbon v. People (G.R. No. 272844, 24 February 2025), the Supreme Court ruled that the prescriptive period for bigamy should not be counted from the registration of the bigamous marriage but from the discovery thereof. This is because in bigamy, the second marriage is generally held in secret, which renders the discovery thereof difficult. The application of constructive notice would render the prosecution of violators of the crime impossible. Here, the bigamous marriage was celebrated in 1999 in Bukidnon, away from the first wife’s residence in Misamis Oriental. It was only discovered by the innocent wife in 2020 and the case was then filed in 2022. There was also no proof that the innocent wife knew of the bigamous marriage earlier. Prescription did not bar the prosecution of the offense.

 The garnishment of property to enforce a writ of execution operates as an attachment, creating a lien that places the property under the jurisdiction of the court that issued the writ. As a result, the property is placed in custodia legis, under the exclusive control of the court. Pursuant to Section 9(c), Rule 39 of the Rules of Court, a judgment for a sum of money may be enforced against the salaries of employees, and as held in Bagbagen v. Perez (G.R. No. 274980, 17 February 2025), this includes the salaries of public officials. They may be garnished once deposited into their bank accounts, because they cease to be public funds, and do not fall under those exempted from execution under Section 13, Rule 39, Rules of Court. The Supreme Court further explained in Bagbagen that the provision exempting salaries under Section 13(i) should be read in conjunction with Article 1708 of the Civil Code, in that it is meant to favor only laboring men or women whose works are manual, and not public officials. Those subject to the exemption usually look to the reward of a day’s labor for immediate or present support, and such persons are more in need of the exemption than the public officials. Thus, the Supreme Court concluded that there is no law exempting the salaries of public officials from garnishment, whereas Article 1708 of the Civil Code grants such exemption to the salaries of laborers.

Beginning 1 July 2025 to 30 September 2025, initiatory pleadings and motions for extensions of time shall also be filed with the Supreme Court electronically through the Philippine Judicial Platform. Starting 1 October 2025, electronic filing and service through the Philippine Judiciary Platform shall be mandatory. The rule further provides that all members of the Philippine Bar shall file electronically using their valid and existing accounts in the Philippine Judiciary Platform. All filings made using a registered account are conclusively presumed to have been made by the person whose name the account is registered to, even if the person has not signed their name in the pleading, motion, or other papers filed. Any person who deliberately allows another person to file any document using their account, or due to their negligence in the safekeeping or security of their account credentials, causes another to file using their account, shall be subject to disciplinary action. Beginning 1 October 2025, the erroneous manner of filing of an initiatory pleading or motion shall be a ground for its dismissal or denial. Any subsequent pleading not filed in accordance with the rule shall be deemed as not filed.

For the sweetheart theory defense to prosper, it must be proven with compelling evidence that: (1) the accused and the victim were lovers; and (2) she consented to the alleged relations. As proof of the relationship, evidence such as letters, documents, photographs, or concrete proof of a romantic nature must be proffered. The second requirement must also be established, for it is as important as the first. Love is not a license for lust. A love affair does not justify rape, for the beloved cannot be sexually violated against her will. (Toralde v. People, G.R. No. 264724, 3 February 2025) In Monroy v. People (G.R. No. 235799, 29 July 2019), the Supreme Court acquitted the accused as the private complainant therein admitted in open court having authored a letter to the accused, and in that letter, she declared her love for the accused, and admitted that the charge of rape was concocted to retaliate against the accused who wanted to go home to the province. However, in Torralde v. People (G.R. No. 264724, 3 February 2025), the accused’s sweetheart defense was not given credence since the alleged proof of the consent – the undated letters purportedly from the victim – were not authenticated, nor did she admit to the same. There was no confirmation also in the letter of the alleged consented sexual relations. The video offered supposedly showing the consent was unauthenticated, and the origin thereof was also admittedly unknown. While the victim admitted to being in a romantic relationship with the accused, this does not negate or rule out the commission of rape.