Case Summary (G.R. No. 198780)
Petitioner and Respondent
- Petitioner: Republic of the Philippines, represented by the Office of the Solicitor General
- Respondent: Liberty D. Albios
Key Dates
- October 22, 2004: Marriage between Fringer and Albios
- December 6, 2006: Albios filed petition for declaration of nullity
- April 25, 2008: RTC rendered judgment declaring the marriage void ab initio
- September 29, 2011: Court of Appeals (CA) affirmed RTC decision
- October 16, 2013: Supreme Court promulgated its decision
Applicable Law
- 1987 Philippine Constitution, Article XV, Section 2
- Family Code of the Philippines:
• Article 1 (Nature and purposes of marriage)
• Article 2 (Consent as essential requisite)
• Article 4 (Effects of absence of essential requisite)
• Articles 45–46 (Vices of consent and grounds for annulment)
• Article 47 (Particulars on fraud) - Rule 45, Rules of Court (petition for review on certiorari)
Factual Background
Liberty Albios and Daniel Fringer were married in Mandaluyong City on October 22, 2004. Albios alleged that the marriage was purely a convenience to obtain American citizenship, with an agreement to pay Fringer USD 2,000 upon successful processing of her immigration petition. They separated immediately after the ceremony, and Fringer never pursued her application.
Ruling of the Regional Trial Court
The RTC of Imus, Cavite, found that the parties entered marriage solely for the purpose of acquiring citizenship and payment, thus lacking real marital intent. It declared the marriage void ab initio for absence of genuine consent and ordered Albios to cease using Fringer’s surname. A motion for reconsideration was denied.
Ruling of the Court of Appeals
The CA affirmed the RTC decision, characterizing the marriage as akin to a “marriage in jest” and holding that the parties did not understand nor intend the legal consequences of marriage. It concluded that the essential element of consent was lacking because their sole purpose was personal gain.
Issue on Review
Whether a marriage contracted solely to obtain foreign citizenship in consideration of money is void ab initio for lack of consent under the Family Code.
Legal Analysis on Consent and Limited-Purpose Marriages
- Under Article 2 of the Family Code, valid consent must be freely given and made before a solemnizing officer; its absence renders the marriage void (Article 4).
- Consent must be real, conscious, and intelligent, free from vitiating factors (fraud, force, intimidation, undue influence).
- Motive (motive to acquire citizenship) is distinct from consent: a deliberate purpose does not impair the free and intelligent intention to contract marriage.
- Comparative jurisprudence on U.S. “limited-purpose” or immigration marriages shows that fraud for immigration does not automatically negate legal validity.
Supreme Court’s Findings
- Genuine Consent: Both parties knowingly and deliberately contracted a valid marriage to secure the legal bond necessary for Albios’s citizenship application.
- Motive vs. Essential Requisites: The agreement for USD 2,000 and the immigration objective do not vitiate consent or fall within the Family Code’s enumerated grounds for annulment.
- Fraud Ground Limitation: Article 45(3) and Article 47 list specific frauds (e.g., concealment of disease, previous conviction); marriage fraud for immigration is not among them. ...continue reading
Case Syllabus (G.R. No. 198780)
Facts
- On October 22, 2004, Daniel Lee Fringer, an American citizen, and Liberty Albios married before Judge Ofelia I. Calo of the Metropolitan Trial Court, Branch 59, Mandaluyong City (MeTC), as shown by Marriage Certificate No. 2004-1588.
- Immediately after the ceremony, the parties separated and never lived as husband and wife.
- Albios alleged that the marriage was entered into in jest, without intention to establish a conjugal and family life or comply with marital obligations.
- She claimed she contracted the marriage to acquire American citizenship and agreed to pay Fringer US$2,000 in consideration; Fringer allegedly never processed her immigration papers, prompting her nonpayment.
Procedural History
- December 6, 2006: Albios filed a petition for declaration of nullity before the RTC of Imus, Cavite (Civil Case No. 1134-06).
- Fringer was duly summoned but did not answer.
- RTC ordered an inquiry into possible collusion; both parties failed to appear, so no determination was made.
- April 25, 2008: RTC rendered judgment declaring the marriage void ab initio and ordered Albios to cease using Fringer’s surname.
- February 5, 2009: RTC denied the Republic’s motion for reconsideration.
- Republic of the Philippines, through the Office of the Solicitor General (OSG), appealed to the Court of Appeals (CA).
- September 29, 2011: CA affirmed the RTC’s nullity decree, finding lack of essential consent.
- The Republic filed a petition for review on certiorari under Rule 45 before the Supreme Court.
Issue
- Whether a marriage contracted solely for the purpose of obtaining American citizenship, in consideration of US$2,000, is void ab initio on the ground of lack of consent.
Ruling of the Regional Trial Court
- Declared the marriage void