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SUBJECT: TOPIC: Date Made: Digest Maker:

Persons Psychological 13 Sept 2018 Aggy


Incapacity
CASE NAME: Castillo v. Castillo
PONENTE: Serene, C.J. Case Date: 18 April 2016

Case Summary: CIVIL CODE WAS THE LAW IN EFFECT DURING THE TIME OF BOTH MARRIAGES.

“The CA states in its Decision that petitioner did not pursue the ground of psychological
incapacity in the RTC. The reason for this finding by the CA while unclear, is irrelevant in this
Petition.”
Guys, the case is under psychological incapacity but these are literally the only sentences that talked
about it so idk. Kasi it was alleged in the original petition in RTC but ayun nga di na daw pinursue???

Renato filed for a declaration of nullity of marriage claiming that his marriage with Lea was
void on the ground that it was bigamous because she had a valid and subsisting marriage
with Benjamin. Lea, on the other hand, claimed that her first marriage was void because
they did not secure a marriage license and neither of them belonged to the same
denomination as their solemnizing officer. RTC ruled in favor of the nullity, while the CA
reversed it.

SC affirmed the decision of CA saying that the Civil Code is law in effect at the time both
marriages were contracted. Under the Civil Code, no judicial declaration was necessary to
establish the nullity of a marriage. Thus, at the time of the second marriage, there was no
valid or subsisting marriage. The second marriage is valid.

Rule of Law/Doctrine:
In the Civil Code, judicial declaration is not needed if the first marriage is void ab initio. The
fact that it is void from the beginning mean that it never existed in the eyes of law. Thus, the
second marriage was valid.

Detailed Facts:
- 25 May 1972 – Lea Castillo and Benjamin Bautistia got married (first marriage)
- 6 January 1979 – Lea Castillo and Renato Castillo got married (second marriage)

On 28 May 2001, Renato filed before the RTC a petition for Declaration of Nullity of
Marriage because it was bigamous and because Lea was psychologically incapacitated.
(The psychological incapacity was not pursued by petitioner in the RTC, accdg. to CA.)

Lea contended that the first marriage was null and void because they did not secure a
marriage license and that neither of them was a member of the denomination to which
the solemnizing officer belonged.

On 3 Jan 2002, Lea filed in the RTC of Parañaque to declare her first marriage void. RTC
declared it to be indeed null and void ab initio. RTC also issued a Certificate of Finality
saying that the decision (nullity of first marriage) has become final and executory.
Renato argued that the first marriage was indeed valid, and regardless of the fact that
she eventually obtained a judicial declaration of nullity, Lea’s first marriage was still
subsisting and valid at the time she and Renato got married.

On 23 March 2007, RTC declared Renato and Lea’s marriage to be void ab initio on the
ground that it was bigamous under Art. 41 of the Family Code. RTC stressed that so long as
there was no judicial declaration of the nullity of the first marriage at the time the second
one was contracted, the first marriage was deemed to be valid and subsisting.

Renato moved for reconsideration in relation with the distribution of their properties, but
was denied by RTC.

Both Renato and Lea appealed to the CA. CA, then, reversed and set aside RTC’s
decision saying that the marriage was valid since the Civil Code was the law in effect
during both marriages; and in the NCC, no judicial declaration is needed for void
marriages.
Issue:
W/N the marriage of Lea and Renato is valid? - YES
Holding:
The Supreme Court agreed with the CA.

The Civil Code was the law in effect at the time the first and second marriages were
contracted. Under the Civil Code, a judicial declaration was not necessary to establish the
nullity of a marriage.

Since Lea and Benjamin’s marriage was void ab initio because they did not have a marriage
license and neither of them belonged to the same denomination as their solemnizing officer.
Thus, it never actually existed in the eyes of law.

This means that at the time Lea and Renato got married, there was no valid and subsisting
first marriage. Thus, Renato and Lea’s marriage is valid.
Ruling:
Petition is denied. Decision of CA is affirmed.
Relevant Provisions