Case Summary (G.R. No. L-42678)
Central Issue: Validity of the Prior Marriage
The pivotal legal question resolved was the status of Lilia’s first marriage to Eduardo A. Maxion, specifically whether the marriage was void or voidable given allegations that both parties were forced into the union. The petitioner admitted to the existence of the prior marriage but contended it was null and void due to coercion. The respondent judge, in pre-trial, established that the force exerted had been admitted, focusing the issue on the legal consequences of such force on the marriage’s validity.
Trial Court’s Ruling on Evidence Presentation
The trial court restricted Lilia from presenting evidence to prove the claim that the first marriage was vitiated by force and to demonstrate that Eduardo A. Maxion was already married at the time of his union with her. The judge justified this on the grounds that the presence of force was already an agreed fact. Consequently, the court ruled that the parties should submit the case for resolution based solely on these "agreed facts." This limitation on evidence led to the petition for certiorari filed by Lilia challenging the trial court’s orders dated March 17 and April 14, 1980.
Supreme Court’s Analysis on Void and Voidable Marriages under the Civil Code
Relying on Article 80 and Article 85 of the Civil Code, the Supreme Court found that even assuming the first marriage was induced by force, such defect renders the marriage merely voidable, not void. A voidable marriage remains valid until annulled by a competent court. Since no annulment was obtained, Lilia’s first marriage was valid at the time she married Karl Heinz Wiegel, rendering the subsequent marriage void ipso facto.
Supreme Court’s Position on the Need for Judicial Declaration
Regarding the claim that Eduardo A. Maxion was already married at the time he married Lilia, the Court held that a prior existing marriage creates a void marriage. However, the void nature of a marriage due to bigamy still requires judicial declaration
...continue readingCase Syllabus (G.R. No. L-42678)
Facts and Procedural Background
- The case involves Family Case No. 483 filed before the Juvenile and Domestic Relations Court of Caloocan City.
- Respondent Karl Heinz Wiegel, as plaintiff, sought the declaration of nullity of his marriage to petitioner Lilia Oliva Wiegel.
- The marriage between Karl and Lilia was celebrated in July 1978 at the Holy Catholic Apostolic Christian Church Branch in Makati, Metro Manila.
- The ground for nullity was the existence of Lilia’s prior marriage to Eduardo A. Maxion, held on June 25, 1972, at Our Lady of Lourdes Church in Quezon City.
- Lilia admitted the prior marriage but claimed it was null and void due to alleged force exerted upon both her and Eduardo to enter into that marriage.
- The central issue for pre-trial was the status of the prior marriage assuming that both parties were forced: whether it was void ab initio or merely voidable.
- Petitioner Lilia contested the validity of the pre-trial order by requesting permission to present evidence on two points:
- That force vitiated the first marriage.
- That Eduardo A. Maxion was already married to another person when he married her.
- The respondent judge denied evidentiary presentation on these points because the existence of force was an agreed fact between the parties.
Issues Presented
- Whether the first marriage, allegedly entered into under force, is null and void or only voidable.
- Whether the petitioner can present additional evidence to prove:
- The prior marriage was vitiated by force.
- The first husband had a prior existing marriage at the time of contracting the marriage with the petitioner.
- Whether petitioner’s marriage to respondent Karl Heinz Wiegel is val