Lim La v. Quintero
REITERATIONFacts
The Antecedents: Plaintiffs, parents of Maria de la Paz Villanueva (Paz Adolfo), a minor aged 14, filed an action to annul the marriage of their daughter to defendant Gabino Quintero. The marriage was solemnized on August 12, 1912, in the Evangelical National Church of Manila, without the consent or knowledge of the plaintiffs. Procedural History: The Court of First Instance of Manila rendered a judgment annulling the marriage, finding it void due to the lack of parental consent. The defendant appealed this decision. The Petition: The plaintiffs prayed for the annulment of the marriage on the ground that their daughter was a minor and that her marriage was contracted without their consent.
Issue(s)
Whether the marriage of a minor, aged fourteen, to Gabino Quintero is void for want of parental consent. Whether the lower court erred in annulling the marriage based on the lack of parental consent.
Ruling
The Supreme Court reversed the judgment of the lower court, ordering the annulment of the judgment annulling the marriage. No costs were awarded.
Ratio Decidendi
On the issue of the validity of the marriage without parental consent: The Court held that the marriage of Maria de la Paz Villanueva, who was fourteen years of age at the time of her marriage, to Gabino Quintero is not void for want of parental consent. The decision was based on the interpretation of General Orders No. 68, which was the governing law at the time. The Court cited previous rulings in Aguilar vs. Lazaro and Lerma vs. Mamaril, which established that a marriage between a man over fourteen years of age and a woman over twelve years of age is valid under General Orders No. 68, and cannot be declared a nullity solely because the consent of the parents was not obtained. The Court found no reason to modify this established doctrine. Therefore, the lower court erred in annulling the marriage on this ground. The parents' assertion that they did not give their consent was noted, but it did not render the marriage void under the prevailing law. On the error of the lower court in annulling the marriage: The Supreme Court found that the lower court erred in annulling the marriage. The annulment was predicated on the lack of parental consent, which, according to the established jurisprudence and the applicable law (General Orders No. 68), did not render the marriage void. The law specified the ages for valid marriage (male over 14, female over 12) and did not make parental consent a requirement that would invalidate the marriage if absent for individuals within these age brackets. The Court reiterated its consistent stance on this matter, emphasizing that the validity of the marriage was not contingent on parental consent for individuals of the ages involved.
Main Doctrine
A marriage entered into by a minor of 14 years of age without the consent of her parents is not void if the applicable law at the time (General Orders No. 68) only requires parental consent for males over 14 and females over 12, and does not declare such marriages void.