Saturday, March 22, 2014

Anaya v.Palaroan, G.R. No. L-27930, Nov. 26, 1970


FACTS: In 1953, Aurora Anaya and Fernando Palaroan were married. In 1954, Palaroan filed an action for annulment of their marriage on the ground that his consent was obtained through force and intimidation. The petition was dismissed. Hence, marriage is subsisting. Later on, Palaroan confessed that he had pre-marital relationship with a close relative of his. Aurora claimed that the non-disclosure of such pre-marital relationship constituted fraud in obtaining her consent. She prayed for annulment of their marriage on such ground.

ISSUE: Whether or not the non-disclosure of a husband to her wife of his pre-marital relationship is a ground for annulment of marriage


HELD: No. It is not enumerated in Family Code Art 46 that would constitute fraud as ground for annulment. In the case at bar, the concealment of his previous relationship does not constitute fraud and therefore would not warrant an annulment of marriage.

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