Friday, November 15, 2013

Tenchavez v. Escaño 15 SCRA 355

FACTS: Pastor Tenchavez, 32, married Vicenta Escano, 27, on February 24, 1948 in Cebu without the knowledge of Escano’s parents. They were planning to elope but this did not materialize because Vicenta went back to her college. When she confessed her marriage to her parents, her parents were angered. But because of the fear the marriage could cause, they wanted them to have a church wedding, which Escano refused upon receiving anonymous letter saying that Tenchavez had another woman. Escano later on moved to Misamis Occidental to escape from the scandal that her marriage stirred in Cebu society. There, a lawyer filed for her a petition drafted by Sen. Pelaez to annul her marriage. She did not sign the petition and case was dismissed. She then applied for a passport, indicating there that she was single, her purpose was to study, and she intends to return after 2 years. In US, she filed a divorce against Tenchanez on the ground of extreme cruelty, entirely mental in character. The divorce was granted. Later on, Escano married an American. On August 8, 1958, she acquired American citizenship. In May 1956, Tenchavez initiated proceeding at bar against Escano, legal separation for bigamy; against Escano parents whom he charged for dissuading Escano to live with him as his wife; and against the Catholic Church for having decreed an annulment of marriage. He asked for 1 million for damages. Vicenta claimed that she had a valid divorce and validly married to her current husband. She also claimed that she was under the undue influence of Pacita Noel whom she charged in conspiracy with Tenchavez.

ISSUE: W/N the divorce was valid

HELD: No. When the divorce was granted, Escano was still a Filipino citizen. She was then subject to Philippine law.


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