Title
Falcis III vs. Civil Registrar General
Case
G.R. No. 217910
Decision Date
Sep 3, 2019
Falcis challenged the Family Code's heterosexual marriage definition, arguing it violated LGBTQI+ rights. The Supreme Court dismissed the case, citing lack of actual controversy and emphasizing legislative, not judicial, resolution for such complex societal issues.

Case Digest (G.R. No. 217910)
Expanded Legal Reasoning Model

Facts:

  • Petition for Certiorari and Prohibition
    • On May 18, 2015, Jesus Nicardo M. Falcis III filed pro se under Rule 65 a petition to declare Articles 1 and 2 of EO 209 (Family Code) unconstitutional and to nullify Articles 46(4) and 55(6), claiming those provisions denied same-sex couples the right to marry.
    • Falcis asserted he was an “open and self-identified homosexual” personally injured by the prohibition against same-sex marriage.
  • Procedural history and interventions
    • June 30, 2015: Civil Registrar General (CRG) ordered to comment.
    • June 22, 2015: Atty. Fernando P. Perito intervened, attacking procedural defects and absence of injury.
    • June 7, 2016: LGBTS Christian Church, Reverend Agbayani, Marlon Felipe, and Maria Arlyn IbaAez intervened with a like petition, alleging denial of marriage licenses.
    • June 8, 2018: Intervenors-oppositors filed opposition-in-intervention, arguing lack of jurisdiction, justiciability, and respect for traditional marriage.

Issues:

  • Procedural and standing questions
    • Is there an actual case or controversy ripe for review?
    • Do petitioner and intervenors have personal, substantial interest (standing)?
    • Does the petition-in-intervention cure the original petition’s procedural defects?
  • Substantive questions (if justiciable)
    • Does limiting marriage to opposite-sex couples violate the right to marry/liberty?
    • Is the opposite-sex restriction a valid exercise of police power under equal protection?
    • Does nonrecognition of same-sex marriage infringe religious freedom?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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