Title
Wiegel vs. Sempio-Diy
Case
G.R. No. L-53703
Decision Date
Aug 19, 1986
Lilia challenged her first marriage's validity, claiming force and bigamy, but the court ruled it voidable, not void, requiring annulment. Her second marriage was deemed invalid as the first remained legally binding.

Case Digest (G.R. No. L-12141)
Expanded Legal Reasoning Model

Facts:

  • Parties and Case Background
    • Petitioner: Lilia Oliva Wiegel
    • Respondents: The Honorable Alicia V. Sempio-Diy (Presiding Judge, Juvenile and Domestic Relations Court of Caloocan City) and Karl Heinz Wiegel
    • Case filed before the Juvenile and Domestic Relations Court of Caloocan City (Family Case No. 483) by respondent Karl Heinz Wiegel seeking declaration of nullity of his marriage to petitioner Lilia Oliva Wiegel.
  • Nature of the Marriage and Grounds for Nullity
    • Marriage of petitioner and respondent Karl Heinz Wiegel was celebrated in July 1978 at the Holy Catholic Apostolic Christian Church Branch in Makati, Metro Manila.
    • The ground for nullity: Petitioner’s prior subsisting marriage to Eduardo A. Maxion, solemnized on June 25, 1972 at Our Lady of Lourdes Church in Quezon City.
  • Petitioner’s Defense and Issues Raised
    • Petitioner admitted the existence of the prior marriage but claimed it was null and void because she and Eduardo A. Maxion were allegedly forced into the marriage.
    • During pre-trial, the agreed issue was the status of the first marriage assuming force was exerted: whether the prior marriage was void or merely voidable.
  • Litigation Events in the Lower Court
    • Petitioner requested to present evidence:
      • That both parties were forced into the first marriage, making it void.
      • That the first husband, Eduardo A. Maxion, was already married to someone else at the time of their marriage in 1972.
    • The respondent judge denied the request to present such evidence, ruling that since the existence of force was already agreed upon, further evidence was unnecessary.
    • The respondent court ordered the case submitted for resolution based on “agreed facts.”
  • Petition for Certiorari
    • Petitioner filed a petition for certiorari assailing:
      • The Order dated March 17, 1980 compelling submission of the case based on agreed facts.
      • The Order dated April 14, 1980 denying her motion to present evidence.

Issues:

  • Whether the prior marriage of petitioner to Eduardo A. Maxion, made under alleged force, is void or merely voidable.
  • Whether petitioner is entitled to present evidence to prove that the first husband was already married to another woman at the time of the marriage in 1972, which could affect the validity of the prior marriage.
  • Whether petitioner’s subsequent marriage to respondent Karl Heinz Wiegel is valid or void in light of the status of the prior marriage.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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