Case Digest (G.R. No. 198780)
Facts:
In Republic of the Philippines v. Liberty D. Albios, decided on October 16, 2013 under G.R. No. 198780, respondent Liberty D. Albios married Daniel Lee Fringer, an American citizen, on October 22, 2004 at the Metropolitan Trial Court, Mandaluyong City. Their Certificate of Marriage was registered as No. 2004-1588. Immediately after the ceremony, the spouses parted ways: Fringer returned to the United States and never communicated further, while Albios never paid the agreed $2,000 consideration for the purported processing of her immigration papers. On December 6, 2006, Albios petitioned the Regional Trial Court (RTC), Imus, Cavite for a declaration of nullity of marriage, alleging lack of intent to establish marital life—a marriage “in jest.” Fringer failed to answer summons. After a failed investigation by the provincial prosecutor for collusion and a pretrial from which Fringer was absent, the RTC rendered judgment on April 25, 2008 declaring the marriage void ab initio. The
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Case Digest (G.R. No. 198780)
Facts:
- Marriage and Nullity Petition
- On October 22, 2004, Daniel Lee Fringer (American citizen) and Liberty D. Albios married before Judge Ofelia I. Calo of the Metropolitan Trial Court, Branch 59, Mandaluyong City (Cert. No. 2004-1588).
- On December 6, 2006, Albios filed a petition for declaration of nullity with the RTC of Imus, Cavite, alleging that the marriage was a “joke” with no intention to live as husband and wife, entered into solely to obtain U.S. citizenship in exchange for USD 2,000.
- Procedural History
- Summons served on Fringer; he neither answered nor appeared at pre-trial or hearings despite due notice.
- April 25, 2008: RTC declared the marriage void ab initio for lack of real consent, ordering Albios to cease using Fringer’s surname.
- February 5, 2009: RTC denied the Republic’s motion for reconsideration.
- September 29, 2011: Court of Appeals affirmed the RTC, holding that the parties’ contract lacked the essential element of consent (“marriage in jest”).
- The Republic of the Philippines (Office of the Solicitor General) filed a petition for review on certiorari under Rule 45; Albios filed a Comment; OSG filed a Reply.
Issues:
- Principal Issue
- Whether a marriage contracted solely for the purpose of securing American citizenship in consideration of USD 2,000 is void ab initio on the ground of lack of consent.
- Subsidiary Questions
- How to distinguish between the parties’ motive (immigration benefit) and their consent under Articles 1, 2, and 4 of the Family Code.
- Whether the “marriage in jest” doctrine applies to marriages of convenience for immigration purposes.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)