Case Digest (G.R. No. 92163) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Reinel Anthony B. De Castro vs. Annabelle Assidao-De Castro (G.R. No. 160172, February 13, 2008), petitioner Reinel Anthony B. De Castro and respondent Annabelle Assidao-De Castro met in 1991 and planned to marry. They applied for a marriage license in September 1994 in Pasig City but when they returned the license had expired. On March 13, 1995, they executed an Affidavit of Cohabitation falsely stating they had lived together as husband and wife for at least five years and were married the same day before Judge Jose C. Bernabe. Immediately after the ceremony, they did not cohabit. On November 13, 1995, respondent gave birth to Reianna Tricia A. De Castro. Respondent supported the child from her earnings as a dentist. On June 4, 1998, respondent filed a complaint for support before the Pasig Regional Trial Court (RTC), alleging a valid marriage and petitioner’s duty to support his wife and child. Petitioner denied the marriage’s validity—asserting a void ab initio contract d Case Digest (G.R. No. 92163) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Relationship
- Petitioner Reinel Anthony B. De Castro and Respondent Annabelle Assidao-De Castro met in 1991, became sweethearts, and planned marriage.
- They applied for a marriage license in September 1994 and began sexual relations in October 1994.
- Marriage Ceremony and Child’s Birth
- The marriage license expired before their second visit; on 13 March 1995 they executed an affidavit (falsely claiming five years’ cohabitation) and were married by Judge Bernabe without subsequent cohabitation.
- On 13 November 1995, respondent gave birth to Reinna Tricia A. De Castro, whom respondent solely supported.
- Proceedings Before the RTC
- 4 June 1998: Respondent filed a support complaint alleging a valid marriage and petitioner’s abandonment; petitioner denied validity of the marriage (void ab initio due to fake affidavit), non-cohabitation, and paternity.
- 16 October 2000: RTC Branch 70 ruled the marriage void (lack of license) but declared petitioner the natural father, ordering him to support wife and child.
- Court of Appeals Decision
- The CA affirmed support award, holding the child legitimate and marriage valid until annulled, invoking the presumption of a subsisting marriage, petitioner’s refusal of DNA testing, and his uncertain testimony on carnal knowledge.
- The CA ruled that the RTC lacked jurisdiction to declare nullity in a support suit (absent prosecuting attorney, collusion safeguards), and that nullity must be pursued in a direct action.
- Supreme Court Proceedings
- Petitioner’s contentions: the marriage is void due to false affidavit; void marriages may be collaterally attacked; no separate nullity suit needed; child is not his.
- Respondent’s Comment: petition is dilatory; marriage validity cannot be collaterally attacked; petitioner was evasive and refused DNA testing.
- OSG’s Comment: supports RTC annulment; cites Niazal v. Bayadog; false affidavit and no license render marriage void; child is illegitimate and entitled to support.
Issues:
- Jurisdiction
- Could the RTC determine the validity of the parties’ marriage in an action for support?
- Filiation
- Is Reinna Tricia A. De Castro the daughter of petitioner and entitled to support?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)