Case Digest (G.R. No. L-16275)
Facts:
- The case involves the Republic of the Philippines (petitioner) and Lolita Quintero-Hamano (respondent).
- Lolita filed a complaint for the declaration of nullity of her marriage to Toshio Hamano, a Japanese national, on June 17, 1996.
- The couple began a common-law relationship in Japan in October 1986 and later cohabited in the Philippines for one month.
- Toshio returned to Japan and remained there for half of 1987.
- Lolita gave birth to their child on November 16, 1987, and they married on January 14, 1988, in Bacoor, Cavite.
- After their marriage, Toshio returned to Japan, promised to return for Christmas, but stopped financial support after two months.
- Despite Lolita's attempts to contact him, Toshio did not respond.
- In 1991, Lolita learned from friends that Toshio had visited the Philippines but did not reach out to her or their child.
- Unable to serve Toshio with summons, Lolita filed an ex parte motion for service by publication, which the trial court granted.
- The trial court allowed Lolita to present evidence ex parte after Toshio failed to respond.
- On August 28, 1997, the Regional Trial Court declared the marriage null and void due to Toshio's psychological incapacity.
- The Office of the Solicitor General appealed this decision, and the Court of Appeals affirmed the ruling on August 20, 2001.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled in favor of the Republic of the Philippines, reversing the Court of Appeals' decision.
- The Court found that the evidence presented by Lolita Quintero-Hamano was insufficient ...(Unlock)
Ratio:
- The Supreme Court highlighted the significance of marriage as a fundamental social institution protected by the state.
- The burden of proof lies with the party seeking to declare a marriage null and void, with any doubts resolved in favor of the marriage's validity.
- Article 36 of the Family Code states that a marriage is void if one party was psychologically incapacitated at the time of the marriage.
- The Court referenced guidelines from the Molina case, requiring psychological incapacity to ...continue reading
Case Digest (G.R. No. L-16275)
Facts:
The case involves the Republic of the Philippines as the petitioner and Lolita Quintero-Hamano as the respondent. The events leading to this case began when Lolita Quintero-Hamano filed a complaint for the declaration of nullity of her marriage to Toshio Hamano, a Japanese national, on June 17, 1996. The couple began a common-law relationship in Japan in October 1986 and later lived together in the Philippines for a month. Toshio returned to Japan and remained there for half of 1987. On November 16, 1987, Lolita gave birth to their child, and they were married on January 14, 1988, by Judge Isauro M. Balderia of the Municipal Trial Court of Bacoor, Cavite. However, shortly after their marriage, Toshio returned to Japan, promising to return for Christmas but subsequently ceased financial support after two months. Despite Lolita's attempts to communicate with him, he did not respond. In 1991, she learned from friends that Toshio had visited the Philippines but did not reach out to her or their child. Unable to serve Toshio with summons due to his absence, Lolita filed an ex parte motion for service by publication, which was granted by the trial court. After Toshio failed to respond to the summons, the trial court allowed Lolita to present her evidence ex parte. On August 28, 1997, the Regional Trial Court of Rizal, Branch 72, declared the marriage null and void, citing Toshio's psychological incapacity to fulfill his marital obligations. The Office of the Solicitor Genera...