Title
Abbas vs. Abbas
Case
G.R. No. 183896
Decision Date
Jan 27, 2013
A Pakistani petitioner sought annulment of his marriage to a Filipino respondent, claiming no valid marriage license was issued. The Supreme Court ruled the marriage void ab initio due to the absence of a license, reversing the CA and reinstating the RTC's decision.

Case Digest (G.R. No. 183896)
Expanded Legal Reasoning Model

Facts:

  • Petition and Background
    • Syed Azhar Abbas, a Pakistani citizen, filed a petition for declaration of nullity of marriage against Gloria Goo Abbas before the RTC of Pasay City (Civil Case No. 03-0382-CFM), alleging absence of a valid marriage license under Article 4, Chapter I, Title I of Executive Order No. 269 (Family Code).
    • The marriage contract recited Marriage License No. 9969967, purportedly issued in Carmona, Cavite on January 8, 1993.
  • Procedural and Evidentiary Developments
    • Syed testified that he and Gloria were married on August 9, 1992 in Taiwan, only learned of the local ceremony on January 9, 1993 in Manila, and never applied for a license in Carmona. In July 2003 he obtained a certification from the Municipal Civil Registrar of Carmona, Cavite, stating that License No. 9969967 was issued to another couple, and that no license was issued in favor of Syed and Gloria.
    • Norberto Bagsic of the Carmona registrar’s office testified that license numbers are sequentially issued and that No. 9969967 was issued solely to Arlindo Getalado and Myra Mabilangan.
  • Respondent’s Proofs
    • Gloria presented Reverend Mario Dauz, who solemnized the January 9, 1993 ceremony at her residence, received the license from Atty. Lorenzo Sanchez, and registered the marriage with the Local Civil Registrar of Manila.
    • Atty. Lorenzo Sanchez (sponsor) testified that a certain “Qualin” secured the license and delivered it to him on January 8, 1993.
    • Felicitas Goo (mother of the bride) corroborated the procurement via Qualin but admitted not reading the license contents.
    • Mary Ann Ceriola’s testimony was stipulated by both parties to confirm sponsorship and attendance.
    • Gloria testified on her own behalf, presented the signed marriage contract, a daughter born June 15, 1993, and noted a bigamy case she filed against Syed.

Issues:

  • Whether a valid marriage license was issued to Syed and Gloria.
  • Whether the Court of Appeals erred in discounting the Carmona Civil Registrar’s certification for lack of explicit “diligent search” language.
  • Whether proof of ceremony, contract signing, and the parties’ conduct as husband and wife can cure the absence of a valid license.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster—building context before diving into full texts.