Title
Ty vs. Court of Appeals
Case
G.R. No. 127406
Decision Date
Nov 27, 2000
A man seeks to nullify his second marriage after his first marriage is declared null and void, but the Supreme Court rules that a judicial declaration of nullity is not necessary for a subsequent marriage to be valid, recognizing the validity of the church wedding and upholding support for the children.
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Case Digest (G.R. No. 127406)

Facts:

  • Ofelia P. Ty sought to overturn the Court of Appeals' decision that upheld the RTC's ruling declaring her marriage to Edgardo M. Reyes null and void.
  • Edgardo M. Reyes was previously married to Anna Maria Regina Villanueva on March 29, 1977, in a civil ceremony, followed by a church wedding on August 27, 1977.
  • This first marriage was declared null and void on August 4, 1980, due to the absence of a valid marriage license and lack of consent.
  • Reyes married Ty on April 4, 1979, in a civil ceremony, followed by a church wedding on April 4, 1982.
  • In 1991, Reyes filed a petition to declare his marriage to Ty null and void, claiming the absence of a marriage license and that he was still legally married to Anna Maria.
  • Ty presented their marriage license and argued for the validity of their union.
  • The RTC ruled in favor of Reyes, declaring the marriage null and void, a decision later affirmed by the Court of Appeals.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of Ofelia P. Ty, declaring her marriage to Edgardo M. Reyes valid and subsisting.
  • The Court reversed the decisions of both the RTC and the Court of Appeals that had declared the marriage null and void. ...(Unlock)

Ratio:

  • A judicial declaration of nullity of a void marriage is not necessary for the validity of a subsequent marriage contracted before such a declaration.
  • Reyes' first marriage was void ab initio due to the lack of a marriage license and consent.
  • The marriage between Reyes and Ty was valid under prevailing jurisprudence...continue reading

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