G.R. No. 173614 - Enrico vs. Heirs of Spouses Medinaceli

Case Summary (G.R. No. 173614)

Relevant Dates and Legal Provisions

Marriage of Eulogio and Trinidad: 14 June 1962.
Death of Trinidad: 1 May 2004.
Marriage of Eulogio to petitioner Lolita: 26 August 2004.
Death of Eulogio: 10 February 2005.
Complaint for declaration of nullity filed by respondents (heirs): 17 March 2005 in RTC Civil Case No. II‑4057.
Controlling substantive and procedural law cited: Family Code (including Article 34), A.M. No. 02‑11‑10‑SC (Sections 1 and 2(a)), and relevant prior decisions such as NiAal v. Bayadog.

Factual Background

Facts Material to the Dispute

Respondents alleged that Eulogio was married to Trinidad (1962) and had seven children with her; Trinidad died on 1 May 2004; Eulogio married petitioner on 26 August 2004 without securing the requisite marriage license; Eulogio died on 10 February 2005. Respondents alleged Article 34 of the Family Code (five‑year cohabitation exemption) was inapplicable because the prior marriage only dissolved by Trinidad’s death three months before the new marriage; respondents also alleged lack of marriage ceremony due to Eulogio’s serious illness. Petitioner claimed she and Eulogio had lived together openly as husband and wife for 21 years and that a ceremony was performed before the Municipal Mayor; petitioner also pleaded as an affirmative defense that only contracting parties may file an action for declaration of nullity.

Trial Court’s Initial Ruling

RTC Order of 11 October 2005 — Dismissal for Lack of Cause of Action

On 11 October 2005 the RTC granted petitioner’s motion to dismiss, holding that A.M. No. 02‑11‑10‑SC, Section 2(a) plainly provides that a petition for declaration of absolute nullity of a void marriage may be filed solely by the husband or the wife. The RTC concluded that the heirs could not substitute for the deceased spouse in bringing such a petition; dismissal was ordered with costs de officio.

Reconsideration and RTC Reversal

RTC Order of 3 May 2006 — Reinstatement Based on NiAal

Respondents moved for reconsideration. The RTC reversed its prior dismissal and reinstated the complaint on the ground that NiAal v. Bayadog permitted heirs to seek declaration of nullity after the death of a party. The RTC reasoned Section 2(a) of A.M. No. 02‑11‑10‑SC applies only where both parties to a void marriage are living; when a party is dead, heirs have vested successional rights that should allow them to challenge the marriage in a separate petition, otherwise they would be prejudiced in their succession rights.

Petitioner’s Recourse to the Supreme Court

Petition for Certiorari and the Question Presented

Petitioner filed a Rule 65 petition with the Supreme Court, challenging the RTC’s reinstatement on the sole legal question whether NiAal or A.M. No. 02‑11‑10‑SC governs the present case — specifically, whether heirs may file a petition for declaration of absolute nullity of a marriage celebrated during the effectivity of the Family Code.

Supreme Court’s Jurisdictional Observations

Hierarchy of Courts and Discretion to Entertain the Petition

The Supreme Court observed petitioner’s use of an abbreviated route bypassing intermediate remedies, reiterated the principle of hierarchy of courts, but exercised discretion to decide the case because it presented a pure question of law of importance and national application.

Supreme Court’s Analysis and Legal Conclusion

Application of the Rule on Nullity Proceedings and Distinction from NiAal

The Supreme Court granted the petition, finding that the RTC committed grave abuse of discretion in reinstating the complaint. The Court distinguished NiAal on the ground that NiAal concerned marriages celebrated before the Family Code’s effectivity and thus applied the Civil Code; by contrast, petitioner’s marriage to Eulogio (26 August 2004) was celebrated during the Family Code era and falls squarely within the prospective scope of A.M. No. 02‑11‑10‑SC. Section 1 of that administrative rule explicitly limits its coverage to petitions under the Family Code. Section 2(a) unambiguously provides that a petition for declaration of absolute nullity of a void marriage may be filed solely by the husband or the wife. The Court applied the maxim that clear statutory language requires no further interpretation and relied on the Rationale accompanying the rule, which states that compulsory or intestate heirs do not have the legal right to file such petitions and instead may question validity in a proceeding for settlement of the

Case Syllabus (G.R. No. 173614)

Caption and Court

Reported at 560 Phil. 673, Third Division of the Supreme Court of the Philippines, G.R. No. 173614, decided September 28, 2007.
Case caption as stated in the source: Lolita D. Enrico, Petitioner, vs. Heirs of Sps. Eulogio B. Medinaceli and Trinidad Catli-Medinaceli, represented by Vilma M. Articulo, Respondents.
Decision authored by Justice Chico-Nazario; concurrence by Justices Ynares-Santiago (Chairperson), Austria-Martinez, Nachura, and Reyes.

Nature of Action and Relief Sought

The petition is a Petition for Certiorari filed under Rule 65 of the 1997 Rules of Civil Procedure.
The petition assails the Regional Trial Court (RTC) of Aparri, Cagayan, Branch 6 Order dated 3 May 2006 in Civil Case No. II-4057, which granted reconsideration of the RTC’s Order dated 11 October 2005 and reinstated respondents’ Complaint for Declaration of Nullity of Marriage.
The dispositive relief sought by petitioner in the Supreme Court was annulment of the RTC’s reinstatement order and dismissal of Civil Case No. II-4057.

Factual Background

Eulogio B. Medinaceli (Eulogio) and Trinidad Catli-Medinaceli (Trinidad) were married on 14 June 1962 in Lal-lo, Cagayan. They begot seven children: Eduardo, Evelyn, Vilma, Mary Jane, Haizel, Michelle and Joseph Lloyd. [Source: complaint; rollo, p. 4]
Trinidad died on 1 May 2004. [Source: complaint; rollo, p. 4]
On 26 August 2004, Eulogio allegedly married petitioner Lolita D. Enrico before the Municipal Mayor of Lal-lo, Cagayan. [Source: complaint; rollo, p. 5]
Eulogio died on 10 February 2005, approximately six months after the marriage to petitioner. [Source: complaint; rollo, p. 5]
Respondents (heirs of Eulogio and Trinidad) filed, on 17 March 2005, an action with the RTC for declaration of nullity of marriage of Eulogio and petitioner. The complaint alleged lack of a requisite marriage license and that Article 34 of the Family Code did not apply to petitioner and Eulogio. [Source: rollo, pp. 4-5]

Respondents’ Allegations (in the Complaint)

Respondents alleged that the marriage between petitioner and Eulogio was entered into without the requisite marriage license.
They asserted Article 34 of the Family Code was inapplicable because petitioner and Eulogio could not have lived together as husband and wife for at least five years before their marriage: Trinidad’s death on 1 May 2004 occurred barely three months prior to the 26 August 2004 marriage to petitioner.
Respondents further alleged lack of marriage ceremony due to Eulogio’s serious illness, which made performance of a ceremony impossible.

Petitioner’s Answer and Defenses

Petitioner asserted she and Eulogio had lived together as husband and wife under one roof for 21 years openly and publicly, invoking the exemption in Article 34 of the Family Code (no license necessary where parties have lived together as husband and wife for at least five years).
Petitioner claimed that from her union with Eulogio were born Elvin Enrico and Marco Enrico, both surnamed Medinaceli, born on 28 October 1988 and 30 October 1991 respectively. [Source: rollo, p. 5]
Petitioner further contended that the marriage ceremony was performed in the Municipal Hall of Lal-lo, Cagayan, and solemnized by the Municipal Mayor.
As an affirmative defense, petitioner argued the action should be dismissed for lack of cause of action on the ground that only the contracting parties while living can file an action for declaration of nullity of marriage.

Relevant Legal Provisions and Authorities Cited

Article 34, Family Code: No license necessary for the marriage of a man and a woman who have lived together as husband and wife for at least five years and without legal impediment; contracting parties must state these facts in an affidavit and the solemnizing officer must state under oath that he ascertained qualifications and found no impediments. [Source: text of Art. 34 in factual summary]
A.M. No. 02-11-10-SC — Rule on Declaration of Absolute Nullity of Void Marriages and Annulment of Voidable Marriages (promulgated by the Supreme Court En Banc; took effect 15 March 2003): Section 1 (Scope) provides that the Rule governs petitions for declaration of absolute nullity of void marriages and annulment of voidable marriages under the Family Code; Section 2(a) provides that a petition for declaration of absolute nullity of void marriage may be filed solely by the husband or the wife. [Source: rollo and textual quotations]
NiAal v. Bayadog, 384 Phil. 661 (2000): prior First Division case holding heirs of a deceased spouse may have standing to assail a void marriage after the death of the spouse; relevant in RTC’s initial reconsideration reasoning but distinguished by the Supreme Court in this decision on basis of difference in applicable law and time of marriage. [Source: rollo, pp. 12-13; citation]
Rationale of the Rules on Annulment of Voidable Marriages and Declaration of Absolute Nullity of Void Marriages, Legal Separation and Provisional Orders: Explains Section 2(a) and states only an aggrieved or injured spouse may file petitions for annulment or declaration of absolute nullity; compulsory or intestate heirs have only inchoate rights prior to the death of their predecessor and may question the validity of a marriage upon the death of a spouse in a proceeding for settlement of the estate. [Source: quoted rationale; rollo]

Procedural History in the Trial Court

RTC Branch 6, Aparri, Cagayan received respondents’ Complaint for Declaration of Nullity of Marriage filed 17 March 2005.
On 11 October 2005, the RTC issued an Order granting petitioner’s affirmative defense/motion to dismiss for lack of cause of action, citing A.M. No. 02-11-10-SC and Section 2(a): the Court interpreted the Rule to mean only husband or wife may file a petition for declaration of absolute nullity and therefore heirs could not substitute for