Tilar vs. Tilar

Regional Trial Courts have exclusive original jurisdiction over petitions for the declaration of nullity of marriage, regardless of whether the marriage was solemnized in a church, because the state governs the civil and legal consequences of marriage as a special contract and an inviolable social institution under the Family Code.

The petitioner and private respondent were married in a Catholic church in 1996. After their relationship deteriorated due to the respondent's alleged psychological incapacity, the petitioner filed a civil case to have their marriage declared void. The trial court, however, refused to hear the case, believing that it had no authority to rule on the validity of a marriage performed by the church, citing the constitutional principle of separation of church and state. This led the petitioner to appeal directly to the Supreme Court on a pure question of law regarding the court's jurisdiction.

• On November 4, 2010, petitioner Jerrysus Tilar filed a petition with the RTC to declare his marriage to the private respondent null and void on the ground of the latter's psychological incapacity under Article 36 of the Family Code.
• The petitioner alleged that he and the respondent were married on June 29, 1996, in a Catholic Church in Poro, Cebu, and had one son.
• He claimed that after the first few months of marriage, the respondent became extremely jealous, violent, extravagant, and a gambler, leading to frequent quarrels and physical harm.
• They separated in 2002, and the respondent was allegedly living with another man in Cebu City.
• A clinical psychologist diagnosed the respondent as suffering from "aggressive personality disorder as well as histrionic personality disorder," which rendered her psychologically incapacitated to fulfill her essential marital obligations.
• The respondent failed to file an Answer after being served with summons, and the Public Prosecutor certified the absence of collusion between the parties.
• On June 3, 2014, the RTC dismissed the petition, not on the merits, but for lack of jurisdiction over the subject matter, and later denied the petitioner's motion for reconsideration.

• The RTC erred in dismissing the case on the ground that the validity of a church marriage is outside the province of its authority.
• The marriage contract is principally governed by civil law, specifically the Family Code, not by the Church's Canon Law.
• The petition seeks to nullify the civil contract of marriage as recognized by the Family Code, which is a separate and distinct matter from any ecclesiastical proceeding for annulment.

• The private respondent did not file an Answer or participate in the proceedings.
• The public respondent, the Republic of the Philippines, through the Solicitor General, filed a Manifestation in Lieu of Comment agreeing with the petitioner that the RTC has exclusive jurisdiction to rule on the validity of marriages pursuant to the Family Code and Batas Pambansa Blg. 129.

• Procedural Issues:
  • Whether the Regional Trial Court has jurisdiction over a petition for declaration of nullity of a marriage that was solemnized in a church.
• Substantive Issues:
  • Whether the validity of a marriage solemnized in a church, for civil purposes, is governed by civil law or by canon law.

• Procedural:
  • Yes, the RTC has jurisdiction. The Supreme Court granted the petition, ruling that the RTC erred in dismissing the case. Under Section 19(15) of Batas Pambansa Blg. 129 (The Judiciary Reorganization Act of 1980), Regional Trial Courts are vested with exclusive original jurisdiction in all actions involving the contract of marriage and marital relations. The law makes no distinction between marriages solemnized by civil authorities and those solemnized by religious authorities.
• Substantive:
  • The validity of a marriage for civil purposes is governed by civil law. The Court held that although marriage is considered a sacrament in the Catholic Church, it simultaneously has civil and legal consequences that are governed exclusively by the Family Code. The petition for nullity under the Family Code pertains to the civil aspect of the marriage, and its resolution is independent of any ecclesiastical annulment proceeding. The principle of separation of church and state is not violated because the court is ruling on the civil contract and not on the religious or sacramental validity of the marriage. The RTC was therefore ordered to proceed with resolving the case based on the evidence presented.

• Jurisdiction of Regional Trial Courts over Marriage Cases — This doctrine, derived from Section 19(15) of Batas Pambansa Blg. 129, grants RTCs exclusive original jurisdiction in all civil actions involving the contract of marriage and marital relations. The Court applied this to rule that the RTC's refusal to hear the case was a clear error, as the law does not distinguish between civil and church-solemnized marriages for jurisdictional purposes.
• Marriage as a Special Contract and Social Institution — Citing the Constitution and Article 1 of the Family Code, the Court reiterated that marriage is not merely a private agreement but a special contract and an inviolable social institution whose nature, consequences, and incidents are governed by law. This principle was used to establish that the state has the authority and interest to regulate all marriages within its jurisdiction, regardless of the manner of solemnization.
• Separation of Church and State — The Court clarified that this constitutional principle was misapplied by the RTC. Ruling on the civil validity of a marriage solemnized in a church does not constitute an encroachment into the domain of the church. The state's action is confined to the civil and legal effects of the marriage contract, which is distinct from an ecclesiastical annulment governed by Canon Law.

"Although, marriage is considered a sacrament in the Catholic church, it has civil and legal consequences which are governed by the Family Code. As petitioner correctly pointed out, the instant petition only seeks to nullify the marriage contract between the parties as postulated in the Family Code of the Philippines; and the declaration of nullity of the parties' marriage in the religious and ecclesiastical aspect is another matter."

• Mariategui v. Court of Appeals — Cited to support the principle that marriage is a social institution in which the public is deeply interested, justifying state regulation.
• Jimenez v. Cañizares — Referenced to emphasize the State's profound interest in the continuity and permanence of marriage as it is foundational to the stability of the State itself.

• 1987 Constitution, Article XV, Section 2 — Cited to establish that marriage is an inviolable social institution that the State is mandated to protect.
• Family Code, Article 1 — Referenced to define marriage as a special contract and an inviolable social institution governed by law, not by mere stipulation of the parties.
• Family Code, Article 36 — This is the substantive legal basis for the petitioner's original petition, which alleges psychological incapacity as a ground for declaring the marriage void.
• Batas Pambansa Blg. 129, Section 19(15) — This was the primary statutory basis for the Court's ruling, as it explicitly grants Regional Trial Courts exclusive original jurisdiction over all actions involving the contract of marriage and marital relations.