G.R. No. 187417 - Capin-Cadiz vs. Brent Hospital and Colleges, Inc.

On 25 May 1972, Lea P. De Leon married Benjamin Bautista.
On 6 January 1979, Lea married Renato A. Castillo.
On 28 May 2001, Renato filed a Petition for Declaration of Nullity of Marriage before the RTC of Quezon City (Branch 84), alleging bigamy and psychological incapacity.

Respondent Lea opposed, asserting her first marriage was void for lack of license and improper solemnization. On 3 January 2002 she filed an action; on 22 January 2003 the RTC of Parañaque City (Branch 260) declared her first marriage null and void ab initio and issued a Certificate of Finality.
On 12 August 2004, Lea filed a Demurrer to Evidence in the Quezon City RTC; Renato opposed, arguing the first marriage was valid and subsisting at the time of their 1979 wedding.
On 8 March 2005, the RTC denied the demurrer; on 23 March 2007 it declared the 1979 marriage null and void ab initio for bigamy under Article 41 of the Family Code. Motions for reconsideration on property distribution were denied.
Both parties appealed. On 20 April 2009, the Court of Appeals reversed the RTC, upholding the validity of the 1979 marriage under the Civil Code; on 16 September 2009 it denied Renato’s motion for reconsideration.
Renato filed a Rule 45 Petition for Review on Certiorari to the Supreme Court; Lea filed a Comment and Renato a Reply.

Whether the Civil Code or the Family Code governs the validity of marriages contracted in 1972 and 1979.

Whether, under the Civil Code, a void marriage (bigamous or otherwise) requires a judicial decree to be considered void and nonexistent before contracting a second marriage.

Whether the Court of Appeals correctly reversed the RTC’s nullity ruling and upheld the validity of the 1979 marriage.