G.R. No.

L-19671 November 29, 1965

PASTOR B. TENCHAVEZ, plaintiff-appellant,

vs.
VICENTA F. ESCAÑO, ET AL.,

FACTS: Vicenta Escaño exchanged marriage vows with Pastor Tenchavez on February 1948.
Unknown to the parents of Vicenta, they were surprised/ more like disgusted about the secret
marriage. To avoid the scandal of the secret marriage, parents of Escano planned to have their
church wedding but Vicente changed her mind because of an anonymous letter stating that
Tenchavez had another woman. The lived separately, exchanged love letters however, not as
endearing as it was before. Vicenta went to US and obtained a divorce decree against Tenchavez in
Nevada. The decree was issued October 21, 1950 and later married Russell Leo Moran and now
living in California. She was naturalized an American in 1958.
In 1956 Tenchavez filed a legal separation for bigamy against Vicenta; against her parents for
having dissuaded and discouraged Vicenta from joining her husband and alienating her affections;
and against the Roman Catholic Church, for having, through it Diocesan Tribunal, decreed the
annulment of the marriage.

ISSUE:
Whether or not the divorce decree obtained abroad valid

RULINGS:
At the time the decree was issued, Vicente Escano, was still a Filipino Citizen, She was then subject
to Philippine law as expressly provided in Article 15 of the Civil Code: “Laws relating to family rights
and duties or to the status, condition and legal capacity of persons are binding upon the citizens of
the Philippines, even though living abroad”. The foreign divorce between Filipino citizens, sought
and decreed after the effectivity of the present Civil Code
is not entitled to recognition as valid in this jurisdiction; and neither is the marriage contracted with
another party by the divorced consort, subsequently to the foreign decree of divorce, entitled to
validity in the country;