Saturday, March 22, 2014

De Castro v. De Castro, G.R. No. 160172, February 13, 2008

FACTS: Reinel and Annabelle met became a couple in 1991.  They applied for a marriage license in September 1994.  When the couple went back to the Office of the Civil Registrar, the marriage license had already expired.  Thus, in order to push through with the wedding despite of absence of marriage license, they executed an affidavit dated 13 March 1995 stating that they had been living together as husband and wife for at least five years.  They got married on the same day.  However, they did not live together as husband and wife. In November 1995, Annabelle gave birth to a daughter, and supported the child on her own. Annabelle then filed a complaint for support against petitioner before the RTC Pasig. In her complaint, respondent alleged that she is married to petitioner and that the latter has a responsibility or obligation to financially support her as his wife and their child. Reinel denied that they are married and claimed that the marriage is void ab initio because the affidavit they jointly executed is a fake. And that he was only forced by Annabelle to marry her to avoid the humiliation that the pregnancy without marriage may bring her. The trial court ruled that the marriage is not valid because it was solemnized without a marriage license. However, it declared petitioner as the natural father of the child, and thus obliged to give her support.

ISSUE: Whether or not their marriage is valid.


HELD: The false affidavit which petitioner and respondent executed so they could push through with the marriage has no value whatsoever; it is a mere scrap of paper.  They were not exempt from the marriage license requirement. Their failure to obtain and present a marriage license renders their marriage void ab initio.

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