Case Digest (G.R. No. 265808)
Facts:
Leoncio L. Melocoton v. Jennifer B. Pring and the Republic of the Philippines, G.R. No. 265808, January 22, 2025, Supreme Court Second Division, Lopez, J., writing for the Court.Petitioner Leoncio L. Melocoton married Susan Jimenez on April 9, 1981 in San Pedro, Laguna. During the alleged subsistence of that marriage, Melocoton married respondent Jennifer B. Pring on May 16, 1987 in Marbel, South Cotabato; their marriage contract was reportedly solemnized by the municipal mayor of Tantangan, South Cotabato. Melocoton also claimed ownership of several real properties and a residential house in the Melocoton compound.
On September 6, 2005, Melocoton filed before the Regional Trial Court (RTC), Civil Case No. 31,055-2005, a Petition for Nullity of Marriage, Correction of Entries with Prayer of Writs of Preliminary Mandatory and Prohibitory Injunction, asserting (1) his marriage to Pring was void for bigamy because his earlier marriage to Jimenez remained subsisting, (2) the solemnizing officer lacked authority, and (3) his signature on the second marriage certificate was forged; he also sought correction of entries in the titles to several properties. Pring answered, claiming she acted in good faith regarding the solemnizing officer’s authority and, alternatively, that property relations should be governed by Article 147 (presumption of joint contribution) and Article 148 of the Family Code; she also asserted she contributed funds to complete the residence.
The RTC (Branch 12, Davao City) rendered judgment on October 26, 2018 declaring the marriage between Melocoton and Pring VOID AB INITIO as bigamous under Article 80 of the Civil Code, directed civil registrars to record the decree, denied Melocoton’s prayer to remove Pring’s name from the titles, and ordered dissolution and equal distribution of the conjugal partnership under Article 144 Civil Code in relation to Article 148 Family Code. Melocoton appealed only the RTC’s property ruling to the Court of Appeals (CA), leaving the nullity ruling unassigned as error.
The Office of the Solicitor General (OSG), representing the Republic, filed an appellee brief contesting the RTC’s finding of bigamy on account of insufficient proof that the first marriage was valid and subsisting at the time of the second marriage; the OSG nonetheless sided with Melocoton as to his exclusive ownership claim over the properties. The CA (CA-G.R. CV No. 05413-MIN) in a May 16, 2022 Decision reversed the RTC and dismissed the petition for annulment of marriage for insufficiency of evidence, holding the marriage to Pring was not prov...(Subscriber-Only)
Issues:
- Did the Court of Appeals commit grave abuse of discretion by reviewing and ruling on the nullity of Melocoton’s second marriage when that issue was not assigned as error on appeal?
- Is the marriage between Leoncio L. Melocoton and Jennifer B. Pring void for bigamy or valid?
- Were the subject properties own...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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