G.R. No. 233413 - Atienza vs. Saluta

Lolita D. Enrico (petitioner) was married to Eulogio B. Medinaceli, whose heirs (respondents) later filed a petition for the declaration of nullity of marriage.
The respondents are the heirs of Spouses Eulogio B. Medinaceli and Trinidad Catli-Medinaceli, with Vilma M. Articulo representing them.

The marriage of Eulogio and Trinidad was celebrated on 14 June 1962 in Lal-lo, Cagayan and produced seven children.
Trinidad died on 1 May 2004.
Eulogio married Lolita D. Enrico on 26 August 2004 before the Municipal Mayor of Lal-lo, Cagayan.
Eulogio passed away on 10 February 2005.

Respondents argued that the marriage between petitioner and Eulogio was void because:

It was entered into without the requisite marriage license;
The conditions of Article 34 of the Family Code (i.e., cohabitation for at least five years) were not met, given that the prior marriage dissolved only upon Trinidad’s death.
The alleged absence of a proper marriage ceremony due to Eulogio’s serious illness.

She and Eulogio lived together openly as husband and wife for 21 years;
A valid marriage ceremony was duly performed in the Municipal Hall of Lal-lo, Cagayan, and duly solemnized by the Municipal Mayor;
The presence of children born from their union further substantiated the marital relationship.

On 11 October 2005, the RTC dismissed the Complaint for Declaration of Nullity of Marriage based on A.M. No. 02-11-10-SC, which states that only the husband or wife may file such a petition.
Respondents filed a Motion for Reconsideration, which led the RTC, via an Order dated 3 May 2006, to reverse its previous decision and reinstate the complaint.
The RTC’s reversal was premised on the ruling in NiAal v. Bayadog, holding that heirs of a deceased spouse have standing to question a void marriage if one party is deceased.
Petitioner filed a Motion for Reconsideration of the RTC’s Order, which was denied on 1 June 2006 for lack of new matter.
Subsequently, petitioner elevated the case to the Supreme Court through a Petition for Certiorari under Rule 65.

The sole issue before the Supreme Court centered on whether the procedural and substantive law to be applied is:

The case law embodied in NiAal v. Bayadog, or
The Rule on Declaration of Absolute Nullity of Void Marriages and Annulment of Voidable Marriages contained in A.M. No. 02-11-10-SC.

An underlying procedural concern involved the proper recourse within the hierarchical structure of the courts.

Whether the exclusive right to file a petition for the declaration of absolute nullity of a void marriage, as mandated by Section 2(a) of A.M. No. 02-11-10-SC, applies to marriages celebrated under the Family Code.
Whether the ruling in NiAal v. Bayadog, which allowed heirs to file a petition for nullity after the death of a spouse, is applicable in the present case where the marriage occurred during the effectivity of the Family Code.
Whether the petitioner’s marriage to Eulogio, having taken place in 2004, squarely falls within the ambit of A.M. No. 02-11-10-SC, thereby precluding the standing of the respondents (heirs) to file such a petition for nullity.