Case Summary (G.R. No. 173614)
Applicable Law and Procedural Background
The case is governed by the Family Code of the Philippines, specifically Article 34 concerning marriage licenses. The procedural backdrop involves the respondents filing a complaint for the declaration of the nullity of Eulogio's marriage to Lolita, claiming it was invalid due to the absence of a requisite marriage license and that the conditions for living together as husband and wife for five years, as stated in Article 34, were not met.
Initial Ruling by the RTC
On October 11, 2005, the RTC dismissed the respondents’ complaint, asserting that only the husband or wife can file for the declaration of nullity of their marriage, as per the Supreme Court’s Administrative Matter No. 02-11-10-SC. The RTC emphasized that the heirs could not substitute the deceased spouse in such proceedings, leading to the dismissal of the case based on lack of cause of action.
Motion for Reconsideration and Reinstatement of the Complaint
The respondents subsequently filed a motion for reconsideration, which the RTC granted on May 3, 2006. The RTC reasoned that the ruling in NiAal v. Bayadog allowed heirs to question a void marriage even after the death of one party. The RTC concluded that under the new rules, the application restricting the petition to the husband or wife solely pertains to situations where both parties are still living, therefore granting legal standing to the heirs after the death of one spouse.
Legal Framework on Marriage Nullity
The Supreme Court observed that the RTC had abused its discretion in reinstating the complaint. It distinguished the NiAal ruling, explaining that it was predicated on marriages celebrated prior to the implementation of the Family Code, thus not applicable to the case at hand, where the invalid marriage occurred under the Family Code provisions.
Supreme Court's Final Decision
The Supreme Court reiterated that under A.M. No. 02-11-10-SC, a petition for declaration of absolute nullity of marriage can only be filed by the husband or wife, implying that neither respondents nor their heirs have legal standing to initiate such a complaint posthumously. The Supreme Court emphasized the clear language of the rule,
...continue readingCase Syllabus (G.R. No. 173614)
Case Overview
- The case involves a Petition for Certiorari filed under Rule 65 of the 1997 Rules of Civil Procedure by petitioner Lolita D. Enrico against the heirs of Spouses Eulogio B. Medinaceli and Trinidad Catli-Medinaceli.
- The petition challenges the Order dated May 3, 2006, from the Regional Trial Court (RTC) of Aparri, Cagayan, which reinstated the respondents' complaint for declaration of nullity of marriage after initially dismissing it on October 11, 2005.
Background of the Case
- Respondents filed a complaint on March 17, 2005, claiming that the marriage between Eulogio and Lolita was void due to the absence of a marriage license and other legal impediments.
- Eulogio was married to Trinidad on June 14, 1962, and they had seven children. Trinidad passed away on May 1, 2004. Eulogio married Lolita on August 26, 2004, and died on February 10, 2005.
- Respondents argue that the marriage license exemption under Article 34 of the Family Code does not apply, as Eulogio and Trinidad's marriage was only dissolved upon Trinidad's death, and the couple could not have lived together for five years prior to the marriage.
Petitioner’s Defense
- Lolita contended that she and Eulogio lived together openly as husband and wife for 21 years and asserted that a marriage ceremony was performed by the Municipal Mayor.
- S