Case Digest (G.R. No. 220828) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Engrace NiAal for herself and as guardian ad litem of the minors Babyline NiAal, Ingrid NiAal, Archie NiAal & Pepito NiAal, Jr. v. Norma Bayadog, G.R. No. 133778, decided on March 14, 2000, Pepito G. NiAal married Teodulfa Bellones on September 26, 1974, and begot the petitioners. On April 24, 1985, Pepito shot and killed Teodulfa. After about one year and eight months, on December 11, 1986, Pepito contracted a second marriage with Norma Bayadog without obtaining a marriage license. They instead executed reciprocal affidavits stating they had lived together as husband and wife for at least five years, invoking the exception under Article 76 of the Civil Code (now Article 34, Family Code). Pepito died in a car accident on February 19, 1997. Thereupon, his children filed in the Regional Trial Court (Branch 59, Toledo City, Cebu) a petition to declare null and void Pepito’s marriage to Norma on the ground of lack of license, as they believed this affected their succession rights Case Digest (G.R. No. 220828) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- First marriage and offspring
- Pepito NiAal married Teodulfa Bellones on September 26, 1974.
- Four children were born of this marriage: Babyline, Ingrid, Archie, and Pepito Jr.
- Killing of first spouse and second union
- On April 24, 1985, Pepito fatally shot Teodulfa.
- On December 11, 1986, Pepito and Norma Bayadog married without a license, executing an affidavit that they had lived together as husband and wife for at least five years.
- Death of Pepito and nullity petition
- Pepito died in a car accident on February 19, 1997.
- The four children filed a petition to declare Pepito’s marriage to Norma void ab initio for lack of a marriage license, asserting impact on their succession rights.
- Norma moved to dismiss, arguing the children lacked cause of action under Article 47 of the Family Code.
- The Regional Trial Court granted dismissal, holding by analogy to Article 47 that the petition must have been filed before Pepito’s death.
Issues:
- Standing
- May the heirs of a deceased person file a petition for declaration of nullity of his marriage after his death?
- Validity of second marriage
- Was Pepito’s marriage to Norma void ab initio for the lack of a marriage license?
- Estoppel
- Are the petitioners estopped from assailing the validity of the second marriage after its dissolution by death?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)