Case Summary (G.R. No. L-53703)
Factual Background
The respondent Karl Heinz Wiegel filed a petition in the Juvenile and Domestic Relations Court seeking a declaration of nullity of his marriage to petitioner Lilia Oliva Wiegel on the ground that Lilia had a prior subsisting marriage to Eduardo A. Maxion solemnized on June 25, 1972. Petitioner admitted the existence of that prior marriage but alleged that she and Eduardo Maxion were compelled to enter into it. The parties thereafter proceeded to pre-trial where they agreed that force had been exerted against both parties of the first marriage. The dispositive question for pre-trial was whether, assuming force against both, the prior marriage was void or merely voidable.
Trial Court Proceedings
During pre-trial petitioner sought leave to present evidence to establish two matters: first, that the first marriage was vitiated by force upon both spouses; and second, that Eduardo Maxion was at the time of that marriage already married to another person. The presiding judge denied the motion to receive further evidence on the ground that the existence of force on both parties had been an agreed fact and therefore the case was to be submitted for resolution on those agreed facts. The petitioner assailed the trial court's Order dated March 17, 1980 compelling submission on agreed facts and the Order dated April 14, 1980 denying admission of additional evidence by filing the present petition for certiorari.
Issues Presented
The principal legal issues were whether petitioner could introduce evidence to prove that the prior marriage was vitiated by force upon both spouses and whether proof that the first husband was already married at the time would affect the validity of the subsequent marriage; and, concomitantly, whether a marriage vitiated by force upon both parties is void or merely voidable for purposes of determining the validity of a later marriage.
The Parties' Contentions
Petitioner contended that she must be allowed to prove that the first marriage was null and void because it was contracted under duress affecting both spouses, and that she must be allowed to prove that Eduardo Maxion had an existing marriage at the time. The respondent judge, and by implication the opposing party, maintained that the question of force had been stipulated in pre-trial and that adjudication should proceed on the agreed facts without reception of the additional evidence.
Ruling of the Supreme Court
The Supreme Court dismissed the petition for certiorari for lack of merit and affirmed the Orders dated March 17, 1980 and April 14, 1980. The Court ordered costs against petitioner. The opinion was delivered by Paras, J., with Feria (Chairman), Fernan, Alampay, and Gutierrez, Jr., JJ., concurring.
Legal Basis and Reasoning
The Court reasoned that proof that the prior marriage was vitiated by force against both spouses was unnecessary to resolve the validity of the subsequent marriage. The Court explained that, under Art. 85, Civil Code, a marriage entered into under force exerted on both spouses is voidable, not void; consequently it remains valid until annulled by judicial action. Because no annulment of the first marriage had been obtained, petitioner remained validly married to Eduardo Maxion at the time she contracted marriage with respondent Karl Heinz Wiegel. Under Art. 80, Civil Code, a marriage contracted while a former marriage subsists is void. The Court further held that evidence of an existing prior marriage of Eduardo Maxion at the time he married
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Case Syllabus (G.R. No. L-53703)
Parties and Procedural Posture
- Lilia Oliva Wiegel was the petitioner and defendant in the trial Family Case No. 483 before the Juvenile and Domestic Relations Court of Caloocan City.
- The Honorable Alicia V. Sempio-Diy was the presiding judge whose March 17, 1980 and April 14, 1980 orders are assailed in this petition for certiorari.
- Karl Heinz Wiegel was the plaintiff in Family Case No. 483 and a respondent in this certiorari proceeding.
- The trial case sought a declaration of nullity of the marriage between Karl Heinz Wiegel and Lilia Oliva Wiegel.
- The petition to this Court assailed the trial judge's order compelling submission on agreed facts and the denial of permission to present additional evidence.
Key Factual Allegations
- Lilia Oliva Wiegel and Eduardo A. Maxion were married on June 25, 1972 at Our Lady of Lourdes Church in Quezon City.
- Lilia Oliva Wiegel and Karl Heinz Wiegel were married in July, 1978 at the Holy Catholic Apostolic Christian Church Branch in Makati, Metro Manila.
- The petitioner admitted the existence of her prior marriage to Eduardo A. Maxion but alleged that the 1972 marriage was vitiated by force exerted upon both spouses.
- The parties agreed in pre-trial that force had been exerted upon both parties to the 1972 marriage.
- The petitioner sought to introduce evidence that the 1972 marriage was vitiated by force and that Eduardo A. Maxion was already married at the time of the 1972 ceremony.
- The respondent judge ruled that evidence was unnecessary because the existence of force had been agreed upon and ordered the case submitted on agreed facts.
Issue Presented
- Whether a marriage vitiated by force exerted upon both parties is void or merely voidable under the Civil Code.
- Whether the trial court erred in precluding petitioner from introducing evidence concerning the vitiation of the prior marriage and the alleged prior marriage of the first husband.
Contentions
- The petitioner contended that the 1972 marriage was null and void because the spouses had been forced into the union and because the first h