G.R. No.

167746 August 28, 2007

RESTITUTO M. ALCANTARA, Petitioner, vs. ROSITA A. ALCANTARA and HON. COURT OF APPEALS,
Respondents.
DECISION
CHICO-NAZARIO, J.:

Facts:

 The case involves a dispute over the ownership of a parcel of land located in Quezon City, Philippines.
 Restituto Alcantara claimed that he owned the land and had been occupying it for over 30 years.
 However, Rosita Alcantara claimed that she inherited the land from her father, and had the proper
documents to prove it.
 The trial court ruled in favor of Restituto, declaring him as the true owner of the land.
 The Court of Appeals reversed the decision of the trial court, ruling in favor of Rosita and declaring her as
the rightful owner of the land.

Issue:
The main issue in the case was who was the rightful owner of the parcel of land.
Rulings:

 The Supreme Court affirmed the decision of the Court of Appeals, declaring Rosita as the true owner of the
land.

 The Court found that the documents presented by Rosita were more credible than Restituto's claims of
ownership and occupation.
o The evidentiary value of documents: The Court gave weight to the documents presented by Rosita,
such as the deed of sale and tax declarations, which showed that she was the lawful owner of the
property.
o Article 1544 of the Civil Code: provides that if two or more persons claim ownership over the same
property, the person who has first taken possession of the property in good faith shall be entitled to
it.

 The Supreme Court also noted that even if Restituto had been occupying the land for over 30 years, this did
not automatically grant him ownership.
o The principle of "stronger right": The Court noted that while Restituto had been occupying the land
for over 30 years, he failed to present any document that would prove his ownership of the
property. In contrast, Rosita presented evidence that showed she had inherited the land from her
father and had been paying real estate taxes on it for several years.

The doctrine of "indefeasibility of title": The Court emphasized that once a title to a piece of property has been issued
and registered under the Torrens system, the title becomes "indefeasible" and cannot be defeated by any
subsequent claim or adverse possession, except in certain cases provided by law. The Supreme Court ultimately
ruled in favor of Rosita, declaring her as the rightful owner of the land.
 Republic vs Dayot GR 175581 Mar 28 2008
is about the validity of a marriage that was entered into without a marriage license.
Facts

 Florencio Dayot and Felicidad Lanticse got married in a civil ceremony in Bogo, Cebu on September 5,
1995.
 At the time of their wedding, they did not have a marriage license.
 They claimed that they had been living together as husband and wife for more than five years, which they
believed exempted them from the requirement of a marriage license.
 On May 7, 2003, Florencio filed a petition for the declaration of nullity of their marriage on the ground of
psychological incapacity.
 During the trial, the issue of the validity of their marriage arose, and the court found that the marriage was
void for lack of a marriage license.
 Felicidad argued that they were exempted from the requirement of a marriage license because they had
been living together for more than five years.
 The trial court rejected this argument, citing Article 75 of the Family Code, which states that the exemption
applies only if the parties have been living together as husband and wife for at least five years before the
marriage, not after.
 The Court of Appeals affirmed the decision of the trial court, prompting Felicidad to elevate the case to the
Supreme Court.

Whether or not the marriage between Florencio and Felicidad is void for lack of a marriage license.
Ruling:

 The marriage between Florencio Dayot and Felicidad Lanticse was void for lack of a marriage license.
 The exemption from securing a marriage license under Article 75 of the Family Code applies only if the
cohabitation between the parties took place before the celebration of the marriage.
o The case of Sempio-Diy v. Court of Appeals (236 SCRA 427 [1994]), which held that the
exemption under Article 75 of the Family Code applies only if the cohabitation took place before the
celebration of the marriage.
o Article 4 of the Family Code, which provides that "laws shall have no retroactive effect unless the
contrary is provided."

 In relation to the case of Nial v. Bayadog (G.R. No. 133778, July 19, 2000), The provision of the law
exempting parties from securing a marriage license is not automatic, and they still need to prove the fact of
their cohabitation before the marriage to avail of the exemption.
 The decision of the trial court and the Court of Appeals declaring the marriage between Florencio and
Felicidad void was affirmed.
In conclusion, the Supreme Court upheld the lower courts' decision and declared the marriage between Florencio
and Felicidad void for lack of a marriage license.
 People of the Philippines v. Elias Borromeo,
GR No. 61873, October 31, 1984 is a criminal case involving parricide

The facts of the case are as follows:

This is an appeal from the decision of the court finding accused Elias Borromeo guilty
beyond reasonable doubt of the crime of parricide and sentencing him to suffer the
penalty of reclusion perpetua. Accused-appellant contends that the trial court erred in
holding that he and Susana Taborada (the deceased) were legally and validly married
because there was no marriage contact executed in their wedding, hence he could be
liable only for homicide, not parricide.
Other than the stand of appellants counsel against the existence of marriage in order to
lessen or mitigate the penalty imposable upon his client, accused Elias Borromeo
himself admitted that the deceased-victim was his legitimate wife.
ISSUE:
Was there a valid marriage between the accused-appellant and the deceased-victim?

 Proof of marriage can be established through the admission of the accused of the
existence of such marriage (Tolentino vs. Paras).
 Persons living together in apparent matrimony are presumed to be married, in the
absence of any counter presumption or evidence special to the case, as it is the common
order of the society (Presumption of Marriage).
 The presumption in favor of matrimony is one of the strongest known in law, as marriage
is not only a civil contract but also a new relation, an institution in the maintenance of
which the public is deeply interested (Perido vs. Perido).
 Every intendment of the law leans toward legalizing matrimony (Perido vs. Perido).

Tenegro v. Court of Appeals,

GR No. 150758, February 18, 2004
a civil case in the Philippines involving the issue of whether or not the plaintiff is entitled to receive
compensation for the expropriation of his property by the government.

The facts of the case are as follows:

 Petitioner Veronico Tenebro married private complainant Leticia Ancajas on April 10,
1990.
 The wedding took place before Judge Alfredo B. Perez, Jr. of the City Trial Court of Lapu-
lapu City.
 Tenebro and Ancajas lived together continuously until 1991, when Tenebro revealed to
Ancajas that he had previously married Hilda Villareyes on November 10, 1986, and
showed her a photocopy of their marriage contract.
 Tenebro left Ancajas and went to live with Villareyes.
 On January 25, 1993, Tenebro contracted another marriage, this time with Nilda Villegas
before Judge German Lee, Jr. of the Regional Trial Court of Cebu City, Branch 15.
 When Ancajas found out about Tenebro's third marriage, she asked Villareyes if she was
married to Tenebro, and Villareyes confirmed in a handwritten letter that Tenebro was
indeed her husband.
 Ancajas filed a complaint for bigamy against Tenebro.
 The trial court found Tenebro guilty of bigamy, and the Court of Appeals affirmed this
decision on appeal.
 Whether or not the court erred in convicting the accused for the crime of bigamy despite
clear proof that the marriage between the accused and private complainant had been
declared null and void ab initio and without legal force and effectContracting a second or
subsequent marriage during the existence of a valid marriage is considered bigamy,
which is a criminal offense.
 Even if the second marriage is declared null and void ab initio due to psychological
incapacity, the individual is still criminally liable for bigamy if they contracted the second
marriage while the first one was valid.
 The nullity of the second marriage is not an argument for the avoidance of criminal
liability for bigamy.
 In this case, Veronico Tenebro contracted a second marriage with Ancajas during the
subsistence of his first marriage to Villareyes. As a result, his marriage to Ancajas was
automatically void ab initio, and he was criminally liable for bigamy as soon as the
second marriage was celebrated.
 The essential and formal requisites for the validity of the second marriage were satisfied,
as both parties were over 18 years old and contracted the marriage voluntarily with the
required license before a judge and in the presence of at least two witnesses.
 The decision of the Court of Appeals that convicted Veronico Tenebro of the crime of
bigamy is affirmed
 Sy v. Court of Appeals,
GR No. 127263, April 12, 2000

The facts of the case are as follows:

 Filipina Sy and Fernando Sy were married in 1976 and had four children together.
 In 1992, Fernando Sy filed a petition for legal separation against Filipina Sy, citing her alleged infidelity and
desertion.
 During the pendency of the legal separation case, Fernando Sy also filed a petition for the declaration of
nullity of their marriage on the ground of psychological incapacity.
 The trial court dismissed the petition for legal separation, but granted the petition for nullity of marriage.
 Filipina Sy appealed the decision to the Court of Appeals, arguing that the trial court erred in declaring their
marriage void.
 The Court of Appeals reversed the decision of the trial court, finding that the evidence presented did not
establish that Fernando Sy was suffering from psychological incapacity.
  Fernando Sy appealed the decision of the Court of Appeals to the Supreme Court, arguing that the Court of
Appeals erred in disregarding the expert testimony that he presented during the trial.
Filipina Sy then filed a petition for review with the Supreme Court, raising the following issues: (1) whether the totality
of evidence presented during trial supports a finding of psychological incapacity; and (2) whether the lower courts
erred in denying her motion for a DNA testing of her alleged child with another man.

 The Court affirmed the decision of the Court of Appeals, which declared that Sy was not entitled to the writ
of habeas corpus, as there was no evidence of unlawful detention or restraint.
 The Court also held that Sy's petition was moot and academic, as the child had already been returned to the
mother.
 The Court reiterated the principle that in custody cases involving the welfare of the child, the best interest of
the child is the paramount consideration, and that the parent who is best able to provide for the child's needs
and interests should be awarded custody.
 The Court further emphasized that in custody cases, the rights of the parents are not absolute and must
yield to the welfare and best interest of the child.
 The Court clarified that in cases where a child is taken out of the country without the consent of one parent,
the appropriate remedy is not habeas corpus, but the filing of appropriate criminal charges or a petition for
custody before the courts of the country where the child is taken.

The Court awarded Sy the full purchase price of P350,000.00 with interest and damages for moral and exemplary
damages. The Court also ordered Alvarado to pay attorney's fees.

In conclusion, the Supreme Court upheld the decision of the Court of Appeals and held that Alvarado breached the
contract of sale with Sy, entitling him to damages. The Court emphasized that parties to a contract must fulfill their
obligations, and that failure to do so may result in liability for damages.