De Castro vs. Assidao-De Castro

Facts:

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 but when they returned the license had expired. On 13 March 1995 they executed an affidavit claiming they had lived together as husband and wife for at least five years and were married the same day by Judge Jose C. Bernabe; however, after the ceremony they did not cohabit as husband and wife.

Respondent gave birth to Reianna Tricia A. De Castro on 13 November 1995 and supported the child from her own income. On 4 June 1998 respondent filed an action for support before the Regional Trial Court (RTC) of Pasig City (eventually Branch 70, JDRC No. 4626), alleging marriage and petitioner’s failure to provide support. Petitioner denied the marriage’s validity (alleging the affidavit was false and the marriage void ab initio), denied paternity, and claimed he had been induced to sign.

In its 16 October 2000 Decision the RTC held the marriage not valid for lack of a marriage license but declared petitioner the natural father and ordered support. Petitioner appealed to the Court of Appeals in CA-GR CV No. 69166. The Court of Appeals affirmed in part but modified: it declared Reianna Tricia the legitimate child of the parties and ruled the marriage valid until annulled by proper court action, criticizing petitioner’s refusal to undergo DNA testing and noting his April 1998 affidavit acknowledging paternity. Petitioner’s motion for reconsideration was denied, and he filed the present petition for review of the Court of Ap...(Pro-only)

Issues:

• Did the trial court have jurisdiction to determine the validity of the marriage between petitioner and respondent in an action for support?
• Is Reianna Tricia A. De Castro the daughter of petitioner (i.e., is filiation...(Pro-only)

Ruling:

• (Pro-only)

Ratio:

• (Pro-only)

Doctrine:

• (Pro-only)