Case Summary (G.R. No. 175581)
Petitioners
- Republic of the Philippines, represented by the Office of the Solicitor General, urging validation of the marriage.
- Felisa Tecson-Dayot, seeking reversal of the Court of Appeals’ Amended Decision.
Respondent
Jose A. Dayot, who initiated a Complaint for Annulment and/or Declaration of Nullity of Marriage on 7 July 1993, alleging fraud in obtaining his consent and absence of any marriage ceremony or license.
Key Dates
• 24 November 1986 – Marriage solemnized at Pasay City Hall under Civil Code Article 76 exception.
• 7 July 1993 – Jose’s Complaint for Annulment and/or Nullity filed with RTC, Biñan, Laguna.
• 26 July 2000 – RTC Decision upholding validity of the marriage.
• 11 August 2005 – Court of Appeals Decision affirming the RTC.
• 7 November 2006 – Court of Appeals Amended Decision declaring marriage void ab initio.
• 1 August 2007 – Supreme Court consolidates G.R. Nos. 175581 and 179474.
Applicable Law
• 1987 Constitution – Framework for rule of law and protection of family.
• Civil Code (pre-Family Code): Articles 53 (essential requisites of marriage), 58 (license requirement), 76 (exception for five-year cohabitation), and 80(3) (void marriages without license).
• Rule 45, Rules of Court – Governing petitions for review.
Factual Background
Jose and Felisa met in early 1986. Over five months, Jose boarded at Felisa’s home. At Pasay City Hall, he signed three blank papers under threat, later discovering in February 1987 they comprised their marriage contract. Felisa denied fraud and asserted genuine mutual consent.
RTC Findings and Ruling
The Regional Trial Court found the marriage valid:
• Jose’s fraud allegations were implausible given surrounding circumstances.
• Jose had acknowledged Felisa as his wife in a 1988 notarized Statement of Assets and Liabilities and on his company ID.
• Jose’s annulment action was barred by the four-year prescription under Civil Code Article 87(4), as he discovered alleged fraud in February 1987 but filed suit only in July 1993.
• Dismissed the complaint and affirmed the marriage’s validity.
First Court of Appeals Decision
On appeal, the Court of Appeals:
• Applied the Civil Code to exclude Family Code provisions.
• Found no fraud under Article 86.
• Held the annulment action prescribed by Article 87(4) and (5) – the suit filed in 1993 was beyond the four-year period from the 1987 discovery.
• Upheld the Article 76 exception, relying on good-faith affirmations in both affidavits by parties and solemnizing officer.
Court of Appeals Amended Decision
Upon Jose’s motion for reconsideration, the Court of Appeals reversed itself:
• Citing NiAal v. Bayadog, it stressed strict compliance with the five-year cohabitation requirement under Article 76.
• Concluded Jose and Felisa cohabited only five months, rendering the affidavit false and the marriage void ab initio for lack of license.
• Ordered cessation of marriage effects and notification to the Local Civil Registrar.
Petitioners’ Arguments
Republic of the Philippines and Felisa contend:
• The presumption of validity of marriage and public policy favor recognition of existing unions.
• A false affidavit under Article 76 should not invalidate a marriage where essential requisites and good-faith reliance by the solemnizing officer exist.
• Jose’s own misconduct bars him from relief.
• Jose is estopped by his long acquiescence and prior bigamy and administrative judgments.
Issues for Supreme Court Review
- Whether a false affidavit under Civil Code Article 76 necessarily voids a marriage celebrated without a license.
- Whether the presumption of validity of marriage or equitable considerations can legitimize a marriage lacking statutory compliance.
- Whether an action to declare a void marriage void ab initio is subject to prescription or equitable estoppel.
Strict Construction of Statutory Exception
• Marriages of exceptional character are strictly construed.
• Article 76 imposes a mandatory five-year cohabitation period preceding marriage.
• Exceptions to license requirements must extend only as language clearly allows.
Factual Determination on Cohabitation Period
• The five-year requirement is factual: Jose and Felisa cohabited roughly five months.
• Findings of both trial and appellate courts, supported by testimony and admissions, cannot be disturbed under Rule 45.
Effect of False Affidavit
• A fabricated affidavit deprives the marriage of the statutory exception to the license requirement.
• A marriage performed without a license or valid exception is void ab initio under Article 80(3).
• Permitting false affidavits undermines public confidence and encourages circumvention of marriage laws.
Presumption of Validity Not Applicable
• The presumption applies to apparent marriages lacking formal proof, not to actual marriages void for statutory non-compliance.
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Case Syllabus (G.R. No. 175581)
Parties
- Petitioners: Republic of the Philippines (Office of the Solicitor General) in G.R. No. 175581; Felisa Tecson-Dayot in G.R. No. 179474
- Respondent: Jose A. Dayot
Facts of the Case
- Jose Dayot and Felisa Tecson-Dayot were married on 24 November 1986 before Rev. Tomas V. Atienza at the Pasay City Hall.
- In lieu of a marriage license, the couple executed an affidavit stating they were of legal age, unmarried, and had lived together as husband and wife for at least five years.
- Jose first learned of the official marriage in February 1987, alleging he was tricked into signing blank papers at the City Hall under threat of violence by Felisa’s brother.
- Despite living together from June 1986, they had not cohabited for the five-year period required by Civil Code Article 76.
Proceedings Below
- July 1993: Jose filed a Complaint for Annulment and/or Declaration of Nullity in RTC Biñan, Laguna (Branch 25), alleging sham marriage, lack of consent, and fraud.
- June 2000: RTC dismissed the Complaint, upholding the validity of the marriage, finding consent genuine and fraud claim prescribed.
- August 2005: Court of Appeals (CA) affirmed the RTC Decision, ruling no fraud, and that the Article 76 exception applied despite a false affidavit.
- November 2006: CA granted Jose’s motion for reconsideration and rendered an Amended Decision declaring the marriage void ab initio for lack of a valid lice