Ty vs. Court of Appeals

For marriages contracted under the Civil Code regime and prior to the ruling in Wiegel v. Sempio-Diy, a prior judicial declaration of nullity of a void first marriage is not a condition precedent for the validity of a subsequent marriage; Article 40 of the Family Code, which requires such a declaration, cannot be applied retroactively if doing so would impair vested rights.

Private respondent Edgardo Reyes filed a civil case to declare his second marriage to petitioner Ofelia Ty null and void. He argued that at the time he married Ty, his first marriage to another woman was still technically subsisting because the judicial decree declaring that first marriage void ab initio was issued only after his wedding to Ty. The lower courts ruled in favor of Reyes, applying modern jurisprudence that strictly requires a judicial declaration of nullity before remarriage, prompting Ty to appeal to the Supreme Court.

• Private respondent Edgardo Reyes contracted a first marriage with Anna Maria Regina Villanueva in civil and church ceremonies in 1977.
• On April 4, 1979, Edgardo married petitioner Ofelia Ty in a civil ceremony, followed by a church wedding on April 4, 1982.
• On August 4, 1980, the Juvenile and Domestic Relations Court declared Edgardo's first marriage to Anna Maria null and void ab initio for lack of a valid marriage license and consent.
• In 1991, Edgardo filed a case to annul his marriage to Ofelia, claiming they lacked a marriage license and that his first marriage was still subsisting when he married Ofelia because the decree of nullity for the first marriage was not yet issued in 1979.
• Ofelia presented evidence, specifically Marriage License No. 5739990, proving a valid license existed for their 1979 marriage, refuting Edgardo's claim regarding the license.
• The Regional Trial Court (RTC) declared the marriage between Ofelia and Edgardo void ab initio for lack of a prior judicial decree of nullity of the first marriage but ordered Edgardo to pay child support.
• The Court of Appeals affirmed the RTC decision, ruling that a judicial declaration of nullity is necessary before a second marriage can be validly contracted, citing Terre v. Terre.

• The marriage to the private respondent was validly contracted with a marriage license, contrary to the respondent's claims.
• The rulings in People v. Mendoza and People v. Aragon should apply, which held that no judicial decree is necessary to establish the invalidity of a void marriage.
• The church wedding in 1982 ratified the civil marriage.
• The provisions of the Family Code requiring a judicial declaration of nullity should not be applied retroactively as it would impair her vested rights and those of her children.

• The marriage to the petitioner is void because it was contracted while the first marriage to Anna Maria was still technically subsisting, as the decree of nullity was issued only in 1980.
• A judicial declaration of nullity of a prior marriage is a strict requirement before contracting a subsequent marriage.
• The marriage to the petitioner lacked a valid marriage license (this argument was factually disproven during trial but was part of the initial complaint).

• Procedural Issues:
  • N/A
• Substantive Issues:
  • Whether a judicial decree of nullity of a prior void marriage is required for the validity of a subsequent marriage contracted before the effectivity of the Family Code and the Wiegel ruling.
  • Whether the petitioner is entitled to moral and exemplary damages.

• Procedural:
  • N/A
• Substantive:
  • The Supreme Court ruled the marriage valid. It held that under the Civil Code and the jurisprudence prevailing in 1979 (Odayat, Mendoza, and Aragon), no judicial decree was necessary to establish the invalidity of a void marriage for purposes of remarriage.
  • The Court refused to apply Article 40 of the Family Code retroactively because doing so would prejudice the vested rights of the petitioner and her children.
  • The Court denied the claim for damages, reasoning that the law does not comprehend an action for damages between husband and wife merely for breach of a marital obligation, and it would be absurd for a husband to pay damages from conjugal funds.

• Retroactivity of the Family Code — The Family Code applies retroactively unless such application impairs vested rights. In this case, applying the requirement for a judicial decree of nullity retroactively was rejected because it would impair the vested rights of the petitioner and her children regarding the validity of their status.
• Necessity of Judicial Declaration of Nullity (Old Rule vs. New Rule) — Under the Civil Code (prior to Wiegel), a void marriage did not strictly require a judicial declaration of nullity to be treated as non-existent for purposes of remarriage; however, under Article 40 of the Family Code, a final judgment declaring the previous marriage void is now explicitly required.
• Clean Hands Doctrine / Estoppel — A party cannot profit from their own deceit and perfidy. The Court refused to allow the private respondent to use his own prior void marriage (which he concealed) as a ground to nullify his marriage to the petitioner.

• "We are now persuaded we cannot play blind to the absurdity, if not inequity, of letting the wrongdoer profit from what the CA calls 'his own deceit and perfidy.'"
• "Logic, if not common sense, militates against such incongruity. Moreover, our laws do not comprehend an action for damages between husband and wife merely because of breach of a marital obligation."

• People v. Mendoza (1954) & People v. Aragon (1957) — Cited as the prevailing jurisprudence at the time the subject marriage was contracted, establishing that no judicial decree was necessary to prove the nullity of a void marriage.
• Odayat v. Amante (1977) — Reaffirmed the Mendoza and Aragon rulings, holding that a judicial decree is not necessary for a void marriage.
• Wiegel v. Sempio-Diy (1986) — Established the stricter rule requiring a judicial declaration of nullity before remarriage; the Court distinguished this case as it was decided after the marriage in question took place.
• Apiag v. Cantero (1997) — Applied the old rule (Odayat, Mendoza, Aragon) to a marriage contracted before the Family Code and Wiegel, serving as the direct precedent for the Court's decision to validate the marriage in this case.
• Terre v. Terre (1992) — Cited by the appellate court as mandatory precedent; the Supreme Court distinguished it, noting the specific timeline of facts in the present case aligned more with Apiag.
• Jison v. Court of Appeals (1998) — Cited to support the principle that the Family Code has retroactive effect only if there is no impairment of vested rights.

• Article 40, Family Code — Explicitly requires a final judgment declaring a previous marriage void for purposes of remarriage; the Court ruled this provision does not apply retroactively to this case.
• Article 83, Civil Code — Pertains to the validity of subsequent marriages; cited to show that the Civil Code contained no express provision requiring a judicial decree of nullity for void marriages.
• Articles 390 and 391, Civil Code — Referenced within Article 83 regarding presumptions of death.