G.R. No. 127406 - Ty vs. Court of Appeals

Civil ceremony held on March 29, 1977, in Manila
Subsequent church wedding on August 27, 1977
Declared null and void ab initio by the Juvenile and Domestic Relations Court of Quezon City on August 4, 1980 due to lack of a valid marriage license and absence of mutual consent in the church wedding

Civil marriage conducted on April 4, 1979, at the City Court of Pasay
Church wedding subsequent held on April 4, 1982, in Makati, Metro Manila
The same marriage license (No. 5739990, issued on April 3, 1979, at Rosario, Cavite) was used for both the civil and church ceremonies

On January 3, 1991, private respondent filed a civil case seeking the declaration of nullity of his marriage with petitioner
Grounds asserted by respondent:

The marriage to petitioner was allegedly contracted without a proper license
At the time of their marriage, he was still legally married to Anna Maria, as the decree nullifying the first marriage had not yet been rendered

Presented a valid marriage license, which she claimed proved the existence of a legal license at the time of the ceremonies
Submitted the August 4, 1980, decree nullifying the marriage to Anna Maria as evidence
Argued that the usage of the same license in both civil and church weddings confirmed the validity and ratification of their marriage

The Regional Trial Court of Pasig (Branch 160) ruled on November 4, 1991, declaring the marriage between petitioner and respondent null and void ab initio and ordered respondent to render monthly support of P15,000.00 for their children
Both parties appealed the RTC’s decision; the Court of Appeals (CA) affirmed the lower court’s ruling on July 24, 1996
The appellate court’s rationale was that a judicial declaration nullifying the first marriage was essential before a subsequent marriage could be validly contracted
Petitioner’s motion for reconsideration was ultimately denied

Argued that a judicial decree nullifying a void marriage was not legally required
Contended that:

The doctrine from People v. Mendoza and People v. Aragon (establishing that no judicial decree is needed to establish the nullity of a void marriage) should apply
The civil effects of the church wedding (which used the same valid marriage license) should be given full legal consequence

Asserted that the appellate court’s failure to consider these issues and its application of subsequent case law (e.g., Domingo v. Court of Appeals) was erroneous

Whether a judicial decree nullifying the first (void) marriage is a necessary prerequisite for a subsequent marriage to be considered valid.

The applicability and relevance of precedents (People v. Mendoza, People v. Aragon, and subsequent cases) in determining whether no judicial decree is needed to establish the nullity of a void marriage.
Whether the retroactive application of the Family Code provisions (notably Article 40) prejudices vested rights of the petitioner and the children.
The validity and legal effects of the church wedding conducted using the same marriage license issued for the civil wedding.
Whether damages may be awarded against the respondent despite the established fact of deceit and perfidy in contracting the marriage.