G.R. No. 272006 - Republic vs. Linney Jean L. Tangarorang and Ramer R. Tangarorang

Petitioner Republic of the Philippines, through the Office of the Solicitor General (OSG), filed a Petition for Review on Certiorari seeking to partially reverse the RTC’s decision declaring the marriage between respondents Linney Jean L. Tangarorang and Ramer R. Tangarorang void ab initio due to psychological incapacity of Ramer under Article 36 of the Family Code.
Respondents are a married couple who begot a child, Sharemahlyne Librada Tangarorang, before their marriage.

Sharemahlyne was born on September 9, 2006.
Linney and Ramer were married on April 12, 2007, shortly after the child’s birth.
Marital difficulties arose from Ramer’s alleged physical, emotional, and verbal abuse, alcoholism, gambling addiction, infidelity, and financial dependence on his parents.
Linney filed a case against Ramer for violation of Republic Act No. 9262 (Anti-Violence Against Women and their Children).
Ramer temporarily took the child away to coerce Linney to drop the VAWC case, returning the child later with apology. The couple separated in 2018.

Linney filed a petition to declare the marriage void on grounds of Ramer’s psychological incapacity.
Psychological evaluation by expert Mita R. Gupana-Lim found Ramer suffering from narcissistic personality disorder and impulse disorder, rendering him incapable to comply with essential marital obligations.
Evidence presented included marriage certificate, child’s birth certificate with affidavit of admission of paternity, psychological report, and judicial affidavits.
The OSG participated as intervenor; Ramer did not contest the case.
The RTC declared the marriage void ab initio and declared Sharemahlyne as an illegitimate child pursuant to Article 165 of the Family Code.
The RTC ordered cancellation of the marriage certificate and allowed Linney to resume her maiden name.

The OSG filed a motion for partial reconsideration contesting only the declaration of Sharemahlyne’s illegitimacy.
Linney argued the child was illegitimate as she was born before the marriage.
The RTC denied the motion, maintaining Sharemahlyne’s status as an illegitimate child, citing the absence of legitimation annotation on her birth certificate.

OSG argued that Sharemahlyne’s legitimacy cannot be collaterally attacked in a nullity petition and that the legitimation by subsequent marriage made her legitimate despite lack of annotation.
Linney counter-argued that legitimation is voided by declaration of nullity, citing Articles 165, 177, and 178 of the Family Code.

Whether the RTC erred in declaring Sharemahlyne Librada Tangarorang an illegitimate child of Linney Jean L. Tangarorang and Ramer R. Tangarorang in the nullity proceeding of their marriage.

Whether the civil status of a child can be resolved as incidental and consequential to nullity of marriage proceedings.

Whether the legitimation of children by subsequent marriage is affected by the declaration of nullity based on psychological incapacity under Article 36.

Whether Linney is a proper party to impugn the legitimacy of her child under Article 182 of the Family Code.