Case Summary (G.R. No. 160172)
Key Dates
- Courtship begins: 1991
- Marriage license application: September 1994
- First sexual relations: October 1994
- Affidavit in lieu of license and ceremony: 13 March 1995
- Child’s birth: 13 November 1995
- Support complaint filed (RTC): 4 June 1998
- RTC decision: 16 October 2000
- Supreme Court decision: 13 February 2008
Applicable Law
- 1987 Philippine Constitution (family and support obligations)
- Family Code of the Philippines: Arts. 4, 34 (license exemption), 172, 175 (filiation proofs)
- Jurisprudence: Niñal v. Bayadog; Nicdao Cariño v. Yee Cariño; Vda. de Jacob v. CA
Facts
Petitioner and respondent became sweethearts in 1991 and intended to marry in 1994. Their marriage license expired before the ceremony. They executed a false affidavit attesting five-year cohabitation and were married on 13 March 1995. They never cohabited afterward. Respondent gave birth to Reianna Tricia on 13 November 1995 and solely supported her. In June 1998, respondent sued petitioner for support, alleging a valid marriage and child legitimacy.
Trial Court Findings
The RTC held the marriage void ab initio for lack of a license but declared petitioner the natural father, obligating him to support the child.
Court of Appeals Ruling
The CA affirmed child support, declaring Reianna legitimate under the presumption of a subsisting marriage until annulled. It refused to entertain a collateral nullity claim in a support case, censured petitioner’s refusal to undergo DNA testing, and relied on his prior affidavit admitting paternity. It modified the RTC decision by upholding the marriage as valid until judicially annulled.
Issues Before the Supreme Court
- Could the RTC determine marital validity in an action for support?
- Is Reianna Tricia the petitioner’s daughter entitled to support?
Jurisdiction to Pass on Marital Validity
The Supreme Court held that a void marriage may be collaterally attacked in any case where its validity is essential. Citing Niñal and Cariño, it affirmed that courts can resolve nullity in support proceedings without a separate annulment action.
Void Marriage for Lack of License
Under Art. 34, only those who cohabit continuously for five years are exempt from a license. The false affidavit here—admitted by both parties—destroyed any exemption. The absence of a license rendered the marriage void ab initio.
Filiation and Support Obligation
Illegitimate filiation may be proven by birth records, admissions in public document
...continue readingCase Syllabus (G.R. No. 160172)
Facts of the Case
- Petitioner and respondent became sweethearts in 1991 and planned to marry.
- They applied for a marriage license in Pasig City in September 1994; the license expired before solemnization.
- On March 13, 1995, they executed an affidavit claiming five years’ cohabitation “as husband and wife” and were married civilly the same day.
- After the ceremony, they did not live together; respondent alone supported their daughter, Reinna Tricia (born November 13, 1995).
Procedural History
- June 4, 1998: Respondent filed a complaint for support in the Pasig RTC, Branch 70.
- Petitioner denied the validity of the marriage (void ab initio for lack of license and false affidavit) and disavowed paternity.
- October 16, 2000: RTC ruled the marriage void for want of license but declared petitioner the natural father and obliged him to support the child.
- Court of Appeals (CA) affirmed with modifications: (1) declared the child legitimate; and (2) held the marriage valid until annulled.
- Petitioner’s motion for reconsideration denied by the CA.
- Petitioner elevated the case to the Supreme Court via petition for review.
Issues Presented
- Whether the RTC had jurisdiction in a support action to determine the validity of the parties’ marriage.
- Whether Reinna Tricia is the daughter of petitioner and thus entitled to support.
Petitioner’s Arguments
- The marriage is void ab initio for lack of a marriage license and for execution of a false cohabitation affidavit.
- A void marr