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Mark Anthony N.

Arellano School of Law
Persons and Family Relations


 July 20, 1965 – Bonifacio de Leon entered Conditional Contract to Sell with PHHC on installment a
parcel of land in QC
 April 24, 1968 – Bonifacio married Anita, civil
 June 20, 1970 – PHHC executed Final Deed of Sale to Bonifacio, with attendant TCT in the name of
Bonifacio, status “single”
 Jan 12, 1974 – Bonifacio sold lot to sister Lita and her husband. Conveying deed of sale did not bear
written consent of Anita
 May 23, 1977 – Bonifacio remarried Anita, church
 Feb 29, 1996 – Bonifacio died
 Deed of Sale executed 1974 only registered with Registrar of Deeds May 8, 1996
 RTC annulled sale of lot from Bonifacio to sister Lita and indemnify heirs
 Lita and husband appealed to CA

WON the surviving spouse has the obligation to pay the creditor of deceased spouse for
money advanced by the latter from the conjugal property for improvement of the same?

 In determining which property is the principal and which is the accessory, the property of greater
value shall be considered the principal. In this case, the lot is the principal and the improvements
the accessories. Since Article 120 of the Family Code provides the rule that the ownership of
accessory follows the ownership of the principal, then the subject lot with all its improvements
became an exclusive and capital property of Alfredo with an obligation to reimburse the conjugal
partnership of the cost of improvements at the time of liquidation of [the] conjugal partnership.
Clearly, Alfredo has all the rights to sell the subject property by himself without need of Josefa‟s

 It is not the petitioners but the estate of her deceased husband which has the obligation to pay the

 Article 120 provides the solution in determining the ownership of the improvements that are
made on the separate property of the spouses at the expense of the partnership or through the
acts or efforts of either or both spouses. Thus, when the cost of the improvement and any
resulting increase in value are more than the value of the property at the time of the
improvement, the entire property of one of the spouses shall belong to the conjugal partnership,
subject to reimbursement of the value of the property of the owner-spouse at the time of the
improvement; otherwise, said property shall be retained in ownership by the owner-spouse,
likewise subject to reimbursement of the cost of the improvement. The subject property was
precisely declared as the exclusive property of Alfredo on the basis of Article 120 of the Family

 It is the owner-spouse who has the obligation to reimburse the conjugal partnership or the spouse
who expended the acts or efforts, as the case may be. Otherwise stated, respondents do not have
the obligation to respect petitioner‟s right to be reimbursed.

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 July 20, 1965 – Bonifacio de Leon entered Conditional Contract to Sell with PHHC on installment a
parcel of land in QC.
 April 24, 1968 – Bonifacio married Anita, civil
 June 20, 1970 – PHHC executed Final Deed of Sale to Bonifacio, with attendant TCT in the name of
Bonifacio, status “single”
 Jan 12, 1974 – Bonifacio sold lot to sister Lita and her husband. Conveying deed of sale did not bear
written consent of Anita
 May 23, 1977 – Bonifacio remarried Anita, church
 Feb 29, 1996 – Bonifacio died
 Deed of Sale executed 1974 only registered with Registrar of Deeds May 8, 1996. RTC annulled sale of
lot from Bonifacio to sister Lita and indemnify heirs. Lita and husband appealed to CA. CA affirmed
RTC judgement of annulment of sale but deleted damages

Whether or not the subject parcel of lot is conjugal property

 Article 160 of the 1950 Civil Code, the governing provision in effect at the time Bonifacio and
Anita contracted marriage, provides that all property of the marriage is presumed to
belong to the conjugal partnership unless it is proved that it pertains exclusively to
the husband or the wife. For the presumption to arise, it is not, as Tan v. Court of Appeals9
teaches, even necessary to prove that the property was acquired with funds of the partnership.
Only proof of acquisition during the marriage is needed to raise the presumption that the
property is conjugal. In fact, even when the manner in which the properties were acquired does
not appear, the presumption will still apply, and the properties will still be considered conjugal.
 Evidently, title to the property in question only passed to Bonifacio after he had fully paid the
purchase price on June 22, 1970. This full payment, to stress, was made more than two (2) years
after his marriage to Anita on April 24, 1968. In net effect, the property was acquired during the
existence of the marriage; as such, ownership to the property is, by law, presumed to belong to the
conjugal partnership.
 Such presumption is rebuttable only with strong, clear, categorical, and convincing evidence.
There must be clear evidence of the exclusive ownership of one of the spouses,15 and the burden of
proof rests upon the party asserting it. The absence of evidence on the source of funding has
called for the application of the presumption under Article 160 in favor of the plaintiffs.
 Petitioners‟ argument that the disputed lot was Bonifacio‟s exclusive property, since it was
registered solely in his name, is untenable. The mere registration of a property in the
name of one spouse does not destroy its conjugal nature. What is material is the time
when the property was acquired.
 The nullity, as we have explained, proceeds from the fact that sale is in contravention of the
mandatory requirements of Art. 166 of the Code. Since Art. 166 of the Code requires the
consent of the wife before the husband may alienate or encumber any real property
of the conjugal partnership, it follows that the acts or transactions executed against
this mandatory provision are void except when the law itself authorized their
 As a final consideration, the Court agrees with the CA that the sale of one-half of the
conjugal property without liquidation of the partnership is void. Prior to the
liquidation of the conjugal partnership, the interest of each spouse in the conjugal
assets is inchoate, a mere expectancy, which constitutes neither a legal nor an
equitable estate, and does not ripen into a title until it appears that there are assets
in the community as a result of the liquidation and settlement. The interest of each
spouse is limited to the net remainder or "remanente liquido" (haber ganancial) resulting from
the liquidation of the affairs of the partnership after its dissolution. Thus, the right of the husband
or wife to one-half of the conjugal assets does not vest until the dissolution and liquidation of the
conjugal partnership, or after dissolution of the marriage, when it is finally determined that, after
settlement of conjugal obligations, there are net assets left which can be divided between the
spouses or their respective heirs.
 Nevertheless, this Court is mindful of the fact that the Tarrosas paid a valuable consideration in
the amount of PhP 19,000 for the property in question. Thus, as a matter of fairness and
equity, the share of Bonifacio after the liquidation of the partnership should be
liable to reimburse the amount paid by the Tarrosas. It is a well-settled principle that no
person should unjustly enrich himself at the expense of another.

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 April 30, 1984 – Civil case for damages that arose from slander filed by sps. Buado against Erlinda
 April 6, 1987 – RTC ruled that Erlinda is liable and ordered her to pay for damages, which was
affirmed by CA and SC
 Oct 14, 1992 – Trial court issued writ of execution, directing the sheriff to collect the indemnification
from Erlinda
 Finding Erlinda‟s personal properties insufficient, sheriff deigned to issue a notice of levy on real
property on execution, and thereafter, a notice of sheriff‟s sale was issued
 Two days prior to the bidding, a Third Party Claim was received at the sheriff‟s office from one
Arnulfo Fulo, prompting spouses Buado to put up a sheriff‟s indemnity bond. Sale proceeded with the
sps. Buado emerging as the highest bidder
 A year after the sale, Romulo Nicol, husband of Erlinda, filed a complaint for annulment of certificate
of sale and damages with preliminary injunction against petitioners and the deputy sheriff, and
alleged that the property was directly levied upon without exhausting the personal properties of

WON the husband considered subsidiarily liable for indemnification of wife’s civil liability
via disposal of conjugal property? NO

 There is no dispute that contested property is conjugal in nature. Article 122 of the Family Code
explicitly provides that payment of personal debts contracted by the husband or the
wife before or during the marriage shall not be charged to the conjugal partnership
except insofar as they redounded to the benefit of the family.

 Unlike in the system of absolute community where liabilities incurred by either spouse by reason
of a crime or quasi-delict is chargeable to the absolute community of property, in the absence or
insufficiency of the exclusive property of the debtor-spouse, the same advantage is not accorded
in the system of conjugal partnership of gains. The conjugal partnership of gains has no
duty to make advance payments for the liability of the debtor-spouse.

 Parenthetically, by no stretch of imagination can it be concluded that the civil obligation arising
from the crime of slander committed by Erlinda redounded to the benefit of the conjugal

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 May 7, 1980 – Mar Tierra Corp via its President, Wilfrido Martinez, applied for P 12M credit line with
Security Bank. Officers bound themselves jointly and severally with the Corp for payment of the loan.
 July 2, 1980 – credit line expanded to P 14M, corresponding new indemnity agreement executed
 Sept 25, 1981 – corp availed of credit and received ~P10M to be paid before Nov 30, 1981. Payment of
~P4.7M for principal and ~P 2.8M for interest paid, but eventually had to close shop in 1984 for
business reversals
 Security Bank filed a complaint for sum of money with prayer for attachment. Other officers had the
case dismissed, leaving Martinez as sole respondent
 Aug 10, 1982 – RTC issued writ of attachment on all real and personal properties of corp and indiv
respondent. Conjugal house and lot of spouses Martinez levied upon
 June 20, 1994 - The RTC rendered its decision. It held respondent corporation and individual
respondent Martinez jointly and severally liable to petitioner for P5,304,000 plus 12% interest per
annum and 5% penalty commencing on June 21, 1982 until fully paid, plus P10,000 as attorney‟s fees.
It, however, found that the obligation contracted by individual respondent Martinez did not redound
to the benefit of his family, hence, it ordered the lifting of the attachment on the conjugal house and
lot of the spouses Martinez.
 SB appealed to CA but RTC decision was held in toto

WON the conjugal partnership of the Martinez spouses could be held liable for the
obligation incurred by individual Martinez?

 Under Article 161(1) of the Civil Code, 8 the conjugal partnership is liable for "all debts and
obligations contracted by the husband for the benefit of the conjugal partnership. If the money or
services are given to another person or entity and the husband acted only as a surety or guarantor,
the transaction cannot by itself be deemed an obligation for the benefit of the conjugal
partnership. Proof must be presented to establish the benefit redounding to the conjugal

 In the absence of any showing of benefit received by it, the conjugal partnership cannot be held
liable on an indemnity agreement executed by the husband to accommodate a third party. In this
case, the principal contract, the credit line agreement between petitioner and respondent
corporation, was solely for the benefit of the latter. The accessory contract (the indemnity
agreement) under which individual respondent Martinez assumed the obligation of a surety for
respondent corporation was similarly for the latter‟s benefit. Petitioner had the burden of proving
that the conjugal partnership of the spouses Martinez benefited from the transaction. It failed to
discharge that burden. To hold the conjugal partnership liable for an obligation pertaining to the
husband alone defeats the objective of the Civil Code to protect the solidarity and well being of the
family as a unit. Petition for attachment on the conjugal property is denied.

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 On July 5, 1987, Marcelino V. Dario died intestate. He was survived by his wife, petitioner Perla
G. Patricio and their two sons, Marcelino Marc Dario and private respondent Marcelino G. Dario
III. Among the properties he left was a parcel of land with a residential house and a pre-school
building built.
 On August 10, 1987, petitioner, Marcelino Marc and private respondent, extrajudicially settled the
estate of Marcelino V. Dario. Accordingly.
 Thereafter, petitioner and Marcelino Marc formally advised private respondent of their intention
to partition the subject property and terminate the co-ownership. Private respondent refused to
partition the property hence petitioner and Marcelino Marc instituted an action for partition.
 Trial court ordered the partition of the subject property in the following manner: Perla G.
Patricio, 4/6; Marcelino Marc G. Dario, 1/6; and Marcelino G. Dario III, 1/6.
 CA held that the family home should continue despite the death of one or both spouses as long as
there is a minor beneficiary thereof. The heirs could not partition the property unless the court
found compelling reasons to rule otherwise. The appellate court also held that the minor son of
private respondent, who is a grandson of spouses Marcelino V. Dario and Perla G. Patricio, was a
minor beneficiary of the family home.

Whether or not partition of the family home is proper where one of the co-owners refuse to
accede to such partition on the ground that a minor beneficiary still resides in the said

 To be a beneficiary of the family home, three requisites must concur: (1) they must be
among the relationships enumerated in Art. 154 of the Family Code; (2) they live in
the family home; and (3) they are dependent for legal support upon the head of the

 Moreover, Article 159 of the Family Code provides that the family home shall continue despite the
death of one or both spouses or of the unmarried head of the family for a period of 10 years or for
as long as there is a minor beneficiary, and the heirs cannot partition the same unless the court
finds compelling reasons therefor. This rule shall apply regardless of whoever owns the property
or constituted the family home.

 The family home shall continue to exist despite the death of one or both spouses or of the
unmarried head of the family. Thereafter, the length of its continued existence is dependent upon
whether there is still a minor-beneficiary residing therein. For as long as there is one beneficiary
even if the head of the family or both spouses are already dead, the family home will continue to
exist (Arts. 153, 159). If there is no minor-beneficiary, it will subsist until 10 years and within this
period, the heirs cannot partition the same except when there are compelling reasons which will
justify the partition. This rule applies regardless of whoever owns the property or who constituted
the family home.

 Marcelino Lorenzo R. Dario IV is dependent on legal support not from his grandmother, but from
his father. Thus, despite residing in the family home and his being a descendant of Marcelino V.
Dario, Marcelino Lorenzo R. Dario IV cannot be considered as beneficiary contemplated under
Article 154 because he did not fulfill the third requisite of being dependent on his
grandmother for legal support. It is his father whom he is dependent on legal support, and
who must now establish his own family home separate and distinct from that of his parents, being
of legal age.

 Legal support, also known as family support, is that which is provided by law, comprising
everything indispensable for sustenance, dwelling, clothing, medical attendance, education and
transportation, in keeping with the financial capacity of the family.

 Professor Pineda is of the view that grandchildren cannot demand support directly from their
grandparents if they have parents (ascendants of nearest degree) who are capable of supporting
them. This is so because we have to follow the order of support under Art. 199.

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 Gerardo B. Concepcion and Ma. Theresa Almonte had a child named Jose Gerardo.
 On December 19, 1991, Gerardo filed a petition to have his marriage to Ma. Theresa annulled on
the ground of bigamy. He alleged that nine years before he married Ma. Theresa on December 10,
1980, she had married one Mario Gopiao, which marriage was never annulled. Gerardo also
found out that Mario was still alive and was residing in Loyola Heights, Quezon City.
 Ma. Theresa did not deny marrying Mario when she was twenty years old. She, however, averred
that the marriage was a sham and that she never lived with Mario at all.
 The trial court ruled that Ma. Theresa‟s marriage to Mario was valid and subsisting when she
married Gerardo and annulled her marriage to the latter for being bigamous. It declared Jose
Gerardo to be an illegitimate child as a result.
 Ma. Theresa felt betrayed and humiliated when Gerardo had their marriage annulled.
 She moved for the reconsideration of the above decision.
 Gerardo opposed the motion. He insisted on his visitation rights and the retention of
„Concepcion‟ as Jose Gerardo‟s surname.

Whether or not the mother right to disavow a child?

 Article 167. The child shall be considered legitimate although the mother may have declared against
its legitimacy or may have been sentenced as an adulteress.
 Gerardo invokes Article 166 (1)(b) of FC, to give credence to Ma. Theresa‟s statement is to allow her
to arrogate unto herself a right exclusively lodged in the husband, or in a proper case, his heirs. A
mother has no right to disavow a child because maternity is never uncertain. Hence, Ma. Theresa is
not permitted by law to question Jose Gerardo‟s legitimacy. Third, to give credence to Ma. Theresa‟s
statement is to allow her to arrogate unto herself a right exclusively lodged in the husband, or in a
proper case, his heirs. A mother has no right to disavow a child because maternity is
never uncertain. Hence, Ma. Theresa is not permitted by law to question Jose Gerardo‟s
legitimacy. He cannot. He has no standing in law to dispute the status of Jose Gerardo. Only Ma.
Theresa‟s husband Mario or, in a proper case, his heirs, who can contest the legitimacy of the child
Jose Gerardo born to his wife. Impugning the legitimacy of a child is a strictly personal right of the
husband or, in exceptional cases, his heirs. Since the marriage of Gerardo and Ma. Theresa was void
from the very beginning, he never became her husband and thus never acquired any right to
impugn the legitimacy of her child.
 First, the import of Ma. Theresa’s statement is that Jose Gerardo is not her legitimate
son with Mario but her illegitimate son with Gerardo. This declaration ― an avowal
by the mother that her child is illegitimate ― is the very declaration that is proscribed
by Article 167 of the Family Code.
 Second, even assuming the truth of her statement, it does not mean that there was never an
instance where Ma. Theresa could have been together with Mario or that there occurred absolutely
no intercourse between them. All she said was that she never lived with Mario. She never claimed
that nothing ever happened between them. Telling is the fact that both of them were living in
Quezon City during the time material to Jose Gerardo‟s conception and birth. Far from foreclosing
the possibility of marital intimacy, their proximity to each other only serves to reinforce such
possibility. Thus, the impossibility of physical access was never established beyond reasonable
 Third, to give credence to Ma. Theresa‟s statement is to allow her to arrogate unto herself a right
exclusively lodged in the husband, or in a proper case, his heirs. A mother has no right to disavow a
child because maternity is never uncertain. Hence, Ma. Theresa is not permitted by law to question
Jose Gerardo‟s legitimacy. Finally, for reasons of public decency and morality, a married woman
cannot say that she had no intercourse with her husband and that her offspring is illegitimate. The
proscription is in consonance with the presumption in favor of family solidarity. It also promotes
the intention of the law to lean toward the legitimacy of children.
 The reliance of Gerardo on Jose Gerardo‟s birth certificate is misplaced. It has no evidentiary value
in this case because it was not offered in evidence before the trial court. The rule is that the court
shall not consider any evidence which has not been formally offered.
 Between the certificate of birth which is prima facie evidence of Jose Gerardo‟s illegitimacy and the
quasi-conclusive presumption of law (rebuttable only by proof beyond reasonable doubt) of his
legitimacy, the latter shall prevail. Not only does it bear more weight, it is also more conducive to
the best interests of the child and in consonance with the purpose of the law.

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 Joanie Surposa Uy filed on 27 October 2003 before the RTC a Petition for the issuance of a decree of
illegitimate filiation against Jose Ngo Chua.
 Uy alleged that Chua who was then married, had an illicit relationship with Irene Surposa.who was
then married, had an illicit relationship with Irene Surposa.
 Joanie denied that he had an illicit relationship with Irene, and that petitioner was his daughter.
Hearings then ensued during which petitioner testified that respondent was the only father she knew;
that he took care of all her needs until she finished her college education; and that he came to visit her
on special family occasions. She also presented documentary evidence to prove her claim of
illegitimate filiation.
 Petitioner JOANIE SURPOSA UY declares, admits and acknowledges that there is no blood
relationship or filiation between petitioner and her brother Allan on one hand and [herein
respondent] JOSE NGO CHUA on the other. This declaration, admission or acknowledgement is
concurred with petitioner‟s brother Allan, who although not a party to the case, hereby affixes his
signature to this pleading and also abides by the declaration herein.
 As a gesture of goodwill and by way of settling petitioner and her brother‟s (Allan) civil, monetary and
similar claims but without admitting any liability, [respondent] JOSE NGO CHUA hereby binds
himself to pay the petitioner the sum of TWO MILLION PESOS (P2,000,000.00) and another TWO
MILLION PESOS (P2,000,000.00) to her brother, ALLAN SURPOSA. Petitioner and her brother
hereby acknowledge to have received in full the said compromise amount.
 Petitioner and her brother (Allan) hereby declare that they have absolutely no more claims, causes of
action or demands against [respondent] JOSE NGO CHUA, his heirs, successors and assigns and/or
against the estate of Catalino Chua, his heirs, successors and assigns and/or against all corporations,
companies or business enterprises including Cebu Liberty Lumber and Joe Lino Realty Investment
and Development Corporation where defendant JOSE NGO CHUA or CATALINO NGO CHUA may
have interest or participation. Chua hereby waives all counterclaim or counter-demand with respect
to the subject matter of the present petition.
 Pursuant to the foregoing, petitioner hereby asks for a judgment for the permanent dismissal with
prejudice of the captioned petition. [Respondent] also asks for a judgment permanently dismissing
with prejudice his counterclaim."

Whether or not filiation can be the subject of judicial settlement?

 It is settled, then, in law and jurisprudence, that the status and filiation of a child cannot be
compromised. Public policy demands that there be no compromise on the status and filiation of a
child. Paternity and filiation or the lack of the same, is a relationship that must be judicially
established, and it is for the Court to declare its existence or absence. It cannot be left to the will
or agreement of the parties.23

 Being contrary to law and public policy, the Compromise Agreement dated 18 February 2000
between petitioner and respondent is void ab initio and vests no rights and creates no obligations.
It produces no legal effect at all. The void agreement cannot be rendered operative even by the
parties' alleged performance (partial or full) of their respective prestations.

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 For several months in 2005, then 21-year old petitioner Jenie San Juan Dela Cruz (Jenie) and then
19-year old Christian Dominique Sto. Tomas Aquino (Dominique) lived together as husband and wife
without the benefit of marriage. They resided in the house of Dominique‟s parents Domingo B.
Aquino and Raquel Sto. Tomas Aquino at Pulang-lupa, Dulumbayan, Teresa, Rizal.
 On September 4, 2005, Dominique died.1 After almost two months, or on November 2, 2005, Jenie,
who continued to live with Dominique‟s parents, gave birth to her herein co-petitioner minor child
Christian Dela Cruz "Aquino" at the Antipolo Doctors Hospital, Antipolo City.
 Jenie applied for registration of the child‟s birth, using Dominique‟s surname Aquino, with the Office
of the City Civil Registrar, Antipolo City, in support of which she submitted the child‟s Certificate of
Live Birth,2 Affidavit to Use the Surname of the Father3 (AUSF) which she had executed and signed,
and Affidavit of Acknowledgment executed by Dominique‟s father Domingo Butch Aquino.4 Both
affidavits attested, inter alia, that during the lifetime of Dominique, he had continuously
acknowledged his yet unborn child, and that his paternity had never been questioned. Jenie attached
to the AUSF a document entitled "AUTOBIOGRAPHY" which Dominique, during his lifetime, wrote
in his own handwriting.
 City Civil Registrar of Antipolo City, Ronald Paul S. Gracia denied Jenie‟s application for registration
of the child‟s name, saying that it violates Rule 7 of Administrative Order No. 1, Series of 2004
(Implementing Rules and Regulations of Republic Act No. 9255 ["An Act Allowing Illegitimate
Children to Use the Surname of their Father, Amending for the Purpose, Article 176 of Executive
Order No. 209, otherwise Known as the „Family Code of the Philippines‟"]) because the autobiography
has no has no signature by Dominique.

Whether or not the unsigned handwritten statement of the deceased father of a minor can
be considered as recognition of paternity?

 Yes, filiation of illegitimate child can be established rather than the admission of filiation in a
public handwritten document signed by the father. It can also be proved by any other means
allowed by the Rules of Court and special laws (Article 172, Paragraph 2 sub 2).

 The Rules on Evidence include provisions on pedigree. The relevant sections of Rule 130 provide
the act or declaration of a person deceased, or unable to testify, in respect to the pedigree of
another person related to him by birth or marriage, may be received in evidence where it occurred
before the controversy, and the relationship between the two persons is shown by evidence other
than such act or declaration. The word "pedigree" includes relationship, family genealogy, birth,
marriage, death, the dates when and the places where these facts occurred, and the names of the
relatives. It embraces also facts of family history intimately connected with pedigree. The fact that
Dominique‟s father and brother proved the filiation of the child by Dominique is admissible.

 Our laws instruct that the welfare of the child shall be the "paramount consideration" in resolving
questions affecting him.

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Be it enacted by the Senate and House of Representatives of the Philippines in Congress assembled:

Section 1. Article 177 of Executive Order No. 209, otherwise known as the "Family Code of the
Philippines", as amended, is hereby further amended to read as follows:

"Art. 177. Children conceived and born outside of wedlock of parents who, at the time of
conception of the former, were not disqualified by any impediment to marry each other, or were
so disqualified only because either or both of them were below eighteen (18) years of age, may be

"Art. 178. Legitimation shall take place by a subsequent valid marriage between parents. The
annulment of a voidable marriage shall not affect the legitimation."

Section 2. Implementing Rules. – The civil Registrar General shall, in consultation with the chairpersons
of the Committee on Revision of Laws of the House of Representatives and the Committee on Youth,
Women and Family Relations of the Senate, the Council for the Welfare of Children, the Department of
Justice (DOJ), the Department of Foreign Affairs (DFA), the office of the Supreme Court Administrator,
the Philippine Association of Civil Registrars (PACR) and the UP Law Center, issue the necessary
rules/regulations for the effective implementation of this Act not later than one (1) month from its

Section 3. Repealing Clause. – All laws, presidential decrees, executive orders, proclamations and/or
administrative regulations which are inconsistent with the provisions of this Act are hereby amended,
modified, superseded or repealed accordingly.

Section 4. Effectivity Clause. – This Act shall take effect fifteen (15) days after its complete publication
in the Official Gazette or in at least two (2) newspapers of national circulation.

Some Summaries of Facts supplied by Lester Ople

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