Case Digest (G.R. No. 187104) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Felicitas Amor-Catalan vs. Court of Appeals, Manila (G.R. No. 167109, February 6, 2007), petitioner Felicitas Amor-Catalan married respondent Orlando B. Catalan on June 4, 1950, in Mabini, Pangasinan. They later migrated to the United States and allegedly became naturalized American citizens. After 38 years of marriage, they secured a U.S. divorce decree in April 1988. On June 16, 1988, Orlando married respondent Merope E. Braganza in Calasiao, Pangasinan, although Merope had a prior subsisting marriage to Eusebio Bristol (married December 21, 1959). Claiming bigamy, Felicitas filed a petition for declaration of nullity of marriage with damages against Orlando and Merope in the Regional Trial Court (RTC) of Dagupan City (Civil Case No. D-10636). The defendants’ motion to dismiss for lack of real party-in-interest was denied, and, after trial, the RTC rendered judgment on October 10, 2000, declaring the second marriage void ab initio and awarding Felicitas ₱300,000 moral damag Case Digest (G.R. No. 187104) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Original Marriage and Alleged Divorce
- Petitioner Felicitas Amor-Catalan married respondent Orlando B. Catalan on June 4, 1950 in Mabini, Pangasinan. They later migrated to the United States and allegedly became naturalized U.S. citizens.
- After 38 years of marriage, Felicitas and Orlando obtained a purported judicial divorce in April 1988 in the U.S.
- Subsequent Marriage and Nullity Petition
- On June 16, 1988, Orlando married respondent Merope E. Braganza in Calasiao, Pangasinan.
- Petitioner filed in the Regional Trial Court (RTC), Dagupan City, Civil Case No. D-10636, a petition for declaration of nullity of Orlando’s subsequent marriage on the ground of bigamy, with a prayer for damages.
- Trial Court and Appellate Proceedings
- The RTC denied respondents’ motion to dismiss for lack of cause of action, conducted trial on the merits, and on October 10, 2000 rendered judgment:
- The Court of Appeals (CA), in CA-G.R. CV No. 69875, on August 6, 2004 reversed and set aside the RTC decision, dismissed the case, and denied petitioner’s motion for reconsideration on January 27, 2005.
- Petitioner filed a petition for review on certiorari in the Supreme Court, raising issues of standing and alleged reversible error by the CA.
Issues:
- Whether petitioner has the required standing (legal personality) to question the nullity of the marriage between Orlando and Merope on the ground of bigamy.
- Whether the CA’s failure to declare the second marriage void constitutes reversible error.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)