De Castro v. Assidao-De Castro
REITERATIONFacts
The Antecedents: Petitioner and respondent met in 1991 and planned to marry. They applied for a marriage license in September 1994. They had their first sexual relation in October 1994 and continued to engage in sexual relations. When they returned to the Civil Registrar, their marriage license had expired. To proceed with the marriage, they executed an affidavit dated March 13, 1995, stating they had lived together as husband and wife for at least five years. They were married on the same date by a Metropolitan Trial Court judge. However, they did not live together as husband and wife after the ceremony. Respondent gave birth to Reinna Tricia A. De Castro on November 13, 1995. Respondent has been solely supporting the child. Procedural History: Respondent filed a complaint for support against petitioner, alleging they were married and that petitioner had failed to provide financial support for her and their child. Petitioner denied the marriage, claiming it was void ab initio due to a fake affidavit and that he was pressured into signing the marriage contract to save respondent from embarrassment due to her pregnancy. He also claimed they never lived together and he never acknowledged the child. The Regional Trial Court (RTC) ruled the marriage invalid for lack of a marriage license but declared petitioner the natural father and obliged him to provide support. Petitioner appealed to the Court of Appeals (CA), arguing grave abuse of discretion by the RTC. The CA affirmed the RTC's decision, declaring the child legitimate and the marriage valid until annulled. The CA noted the presumption of a subsisting marriage, petitioner's refusal to undergo DNA testing, and his admission of paternity in a separate affidavit. The CA also ruled that the RTC improperly declared the marriage void in an action for support, as such a declaration requires state participation and a direct proceeding. The CA modified the RTC's decision to declare the child legitimate and the marriage valid until annulled. The Petition: Petitioner sought review of the CA's decision, arguing the RTC correctly annulled the marriage due to the absence of a marriage license and the falsity of the affidavit. He contended that a void marriage can be collaterally attacked and that the RTC had jurisdiction to determine its invalidity as an affirmative defense in the support action. He also argued that the CA erred in declaring the child his legitimate child given the marriage's nullity and his denial of paternity.
Issue(s)
Whether the trial court had jurisdiction to determine the validity of the marriage between petitioner and respondent in an action for support. Whether the child, Reinna Tricia A. De Castro, is the daughter of the petitioner and, therefore, entitled to support.
Ruling
The petition is granted in part. The assailed Decision and Resolution of the Court of Appeals are SET ASIDE, and the decision of the Regional Trial Court Branch 70 of Pasig City is REINSTATED.
Ratio Decidendi
On the issue of the trial court's jurisdiction to determine the validity of the marriage in an action for support: The Court held that the trial court had jurisdiction to determine the validity of the marriage. It reiterated the principle that the validity of a void marriage may be collaterally attacked. Citing Niñal v. Bayadog, the Court clarified that for purposes other than remarriage, such as the determination of legitimacy or illegitimacy of a child or the right to support, a court may pass upon the validity of a marriage even in a suit not directly instituted to question it, provided it is essential to the determination of the case. The Court emphasized that evidence must be adduced to prove the grounds rendering the marriage void. In this case, the evidence clearly showed the absence of a marriage license and the falsity of the affidavit of cohabitation, rendering the marriage void ab initio. The Court stressed that the false affidavit had no legal value and did not exempt the parties from the marriage license requirement. On the issue of the child's paternity and filiation: The Court found that the child is the petitioner's illegitimate daughter and is therefore entitled to support. Illegitimate children can establish their filiation through various means, including admissions in public or private documents. The Certificate of Live Birth listed the petitioner as the father. Furthermore, the petitioner himself executed an affidavit admitting he is the legitimate father of the child. The Court also gave weight to the trial court's findings, which were supported by the petitioner's own testimony admitting sexual relations with the respondent, the respondent's pregnancy resulting in their marriage, and photographic evidence of the marriage ceremony, including the petitioner placing the wedding ring on the respondent's finger and kissing her.
Main Doctrine
A marriage solemnized without a marriage license is void ab initio. An affidavit falsely stating that the parties had lived together as husband and wife for at least five years cannot substitute for a valid marriage license. The validity of a void marriage may be collaterally attacked, and a court may pass upon the validity of a marriage in a suit not directly instituted to question the same, if it is essential to the determination of the case, such as an action for support.