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Title	IDs & Reference #s	Background	Primary Holding	Subject Matter
Green vs. Green (17th February 2025)	AK221240 G.R. No. 255706	In 2006, Jeffery A. Green, a United States Navy retiree, met Rowena Manlutac in a bar in Angeles City. They developed a relationship, during which Jeffery was aware Rowena had two children from a previous relationship and Rowena knew Jeffery's divorce was still pending. In 2008, Rowena gave birth to a daughter, Abigail, whom Jeffery acknowledged as his own. They married on May 8, 2010. Following the marriage, Jeffery discovered Rowena's infidelity, pathological gambling, deceitfulness regarding finances and the paternity of Abigail, and accumulation of significant debt, which led him to file a petition to have their marriage declared void.	Psychological assessments based on the testimonies of the petitioner, respondent, respondent's mother, and a mutual friend can be given credence in proving psychological incapacity, especially when there is no reason to believe the testimonies are fabricated. The declaration of nullity of marriage is warranted as long as the totality of the evidence clearly and convincingly establishes one spouse's psychological incapacity to perform essential marital obligations.	Persons and Family Law Article 36, Family Code
Cabutaje vs. Republic (15th January 2025)	AK080199 G.R. No. 248569	Ericson Cabutaje and Romelia Cabutaje married in 2003 and had a daughter. To provide for their family, both spouses eventually worked abroad in Taiwan, but their relationship deteriorated due to distance and Romelia's inconsistent financial support. After her contract ended, Romelia returned to the Philippines, took their daughter, but then left the child in her sister's care to work in Hong Kong. She ceased providing financial support and entered into another romantic relationship. These events prompted Ericson to file a petition to have their marriage declared void, alleging that both he and Romelia were psychologically incapacitated to fulfill their essential marital obligations.	The marriage is declared void ab initio on the ground of respondent Romelia A. Cabutaje's psychological incapacity, which was sufficiently established through the totality of evidence, including expert testimony based on collateral interviews and testimonies of witnesses who knew the respondent, without the need for the respondent's direct personal examination.	Persons and Family Law Article 36, Family Code
SHELA BACALTOS ASILO vs. PRESIDING JUDGE MARIA LUISA LESLE2 G. GONZALESBETIC, Branch 225, Regional Trial Court, Quezon City (10th July 2024)	AK524241 G.R. No. 232269	Shela Bacaltos Asilo, a Filipino citizen, married Tommy Wayne Appling, a foreign national, in Hong Kong on November 1, 2002. They lived together in Hong Kong until their separation on August 11, 2011. Subsequently, they obtained a divorce decree in Hong Kong. To have the divorce recognized in the Philippines and to be able to revert to her maiden name, Shela filed a Petition for Recognition of a Foreign Judgment of Divorce with the Regional Trial Court of Quezon City.	In a petition for recognition of a foreign divorce decree under Article 26(2) of the Family Code, the nationality of the alien spouse at the time of the divorce and the specific national law of the alien spouse that recognizes the divorce and capacitates them to remarry are ultimate facts that must be specifically alleged in the initiatory pleading and duly proven during trial to establish a cause of action.	Persons and Family Law Family Code, Article 26(2)
Lanuza vs. Lanuza (17th April 2024)	AK077510 953 Phil. 796 , G.R. No. 242362	Leonora O. Dela Cruz-Lanuza and Alfredo M. Lanuza, Jr. were married in June 1984 and had four children. According to Leonora, their married life started smoothly but later deteriorated when Alfredo began coming home late, neglecting his family, and engaging in illicit affairs. The couple eventually separated in 1994. Following their separation, Alfredo abandoned the family completely, failed to provide any financial support, and reportedly entered into two subsequent marriages with other women, which became the basis for Leonora's petition to have their marriage declared void.	Unjustified absence from the marital home for decades, coupled with other manifestations such as infidelity and contracting subsequent marriages, can be considered as part of the totality of evidence proving that a person is psychologically incapacitated to comply with the essential obligations of marriage under Article 36 of the Family Code.	Persons and Family Law Family Code, Article 36
Republic of the Philippines vs. Ruby Cuevas Ng a.k.a. Ruby Ng Sono (27th February 2024)	AK961631 G.R. No. 249238	Respondent Ruby Cuevas Ng, a Filipino citizen, married Akihiro Sono, a Japanese national, in the Philippines in 2004. They subsequently moved to Japan and had a child. After their relationship soured, they jointly secured a "divorce decree by mutual agreement" in Japan in 2007. This led Ng to file a petition in the Philippines for the judicial recognition of their foreign divorce to allow her to remarry under Philippine law.	A foreign divorce obtained by mutual agreement between a Filipino spouse and a foreign spouse is within the ambit of Article 26, paragraph 2 of the Family Code and may be judicially recognized in the Philippines, as the law does not distinguish between divorces obtained through judicial proceedings and those obtained through other means, so long as the divorce is validly obtained abroad and capacitates the foreign spouse to remarry.	Persons and Family Law Article 26(2), Family Code
Georfo vs. Republic (6th March 2023)	AK019581 937 Phil. 518 , G.R. No. 246933	Agnes Padrique Georfo and Joe-Ar Jabian Georfo were married in 2002 after Agnes's family presumed they had engaged in premarital sex. The marriage was characterized by conflict with Joe-Ar's family, physical abuse, infidelity on Joe-Ar's part, and his failure to provide financial support. After eight years of separation, Agnes filed a petition to declare their marriage void on the ground of Joe-Ar's psychological incapacity, presenting her own testimony, her sister's corroborating testimony, and a psychological report from an expert who diagnosed Joe-Ar without personally examining him.	Psychological incapacity under Article 36 of the Family Code is a legal concept, not a medical illness, and its existence can be proven by clear and convincing evidence showing a party's personality structure renders them truly unable to comprehend and discharge their essential marital obligations; consequently, a psychiatric examination of the alleged incapacitated spouse is not required, and an expert's psychological evaluation based on collateral information is admissible and can be given probative value as part of the totality of evidence.	Persons and Family Law Article 36, Family Code
Clavecilla vs. Clavecilla (6th March 2023)	AK396412 937 Phil. 488 , G.R. No. 228127	The petitioner, Fernando Clavecilla, and respondent, Marivic Clavecilla, met and married while working as overseas Filipino workers in Saudi Arabia in the late 1980s. After nearly two decades of marriage and having one child, their relationship deteriorated, prompting Fernando to file a petition for the declaration of nullity of their marriage on the ground of psychological incapacity.	Either spouse, regardless of whether they are the one alleged to be psychologically incapacitated, may initiate a petition to declare the nullity of marriage under Article 36 of the Family Code, and the doctrine of unclean hands cannot be invoked to bar such a petition.	Persons and Family Law Family Code, Article 36
Republic vs. Kikuchi (22nd June 2022)	AK901162 1020 SCRA 376 , G.R. No. 243646	Jocelyn Asusano Kikuchi, a Filipino, married Fumio U. Kikuchi, a Japanese national, in 1993. In 2007, they jointly filed for and obtained a divorce before the City Hall of Sakado City, Saitama Prefecture, Japan. Subsequently, Jocelyn sought to have this foreign divorce recognized in the Philippines to regain her capacity to remarry under Philippine law, leading her to file a petition for judicial recognition.	For a petition for judicial recognition of a foreign divorce to prosper under Article 26 of the Family Code, the petitioner must prove two distinct elements: (1) the fact of the divorce, and (2) the national law of the foreign spouse allowing for the divorce. While an authenticated "Acceptance Certificate" from a Japanese local government office suffices to prove the fact of an administrative divorce, a mere photocopy of an unofficial English translation of the foreign law, even if stamped by the foreign embassy's library, is insufficient to prove the foreign law itself.	Persons and Family Law Family Code, Article 26
Cayabyab-Navarrosa vs. Navarrosa (20th April 2022)	AK399202 1018 SCRA 644 , G.R. No. 216655	Petitioner Lovelle Shelly S. Cayabyab-Navarrosa and respondent Mark Anthony E. Navarrosa met in 2001 and became lovers. In 2004, they moved to Singapore to work. After the petitioner became pregnant, they returned to the Philippines and married on August 15, 2006. The respondent had lost his job prior to the wedding, making the petitioner the sole provider. The marriage quickly deteriorated due to the respondent's financial irresponsibility, emotional and verbal abuse, and eventual abandonment of the petitioner and their child in August 2007, prompting the petitioner to file for the nullity of their marriage.	Psychological incapacity under Article 36 of the Family Code is a legal, not a medical, concept, and it is not a mental incapacity or a personality disorder that must be proven through expert opinion; rather, it is a party's genuine inability to comprehend and comply with their essential marital obligations, which can be established by clear and convincing evidence of their dysfunctional behavior during the marriage, even without a formal psychological diagnosis of the incapacitated spouse.	Persons and Family Law Article 36, Family Code
Cariaga vs. Republic (7th December 2021)	AK229521 1010 SCRA 398 , G.R. No. 248643	Lovelle Cariaga and Henry Cariaga were college sweethearts who married in 2000 after Lovelle became pregnant. Their parents arranged for a friend to handle the documentary requirements for the civil wedding. After thirteen years and three children, the couple separated in 2013 due to differences. In 2015, upon learning that Henry was in a relationship with another woman, Lovelle consulted a lawyer to have her marriage annulled. On her lawyer's advice, she verified the authenticity of the marriage license indicated on their Certificate of Marriage with the Civil Registry of Quezon City. This investigation led to the discovery that the license was issued to another couple, prompting her to file a petition to declare her marriage void.	A certification from the local civil registrar stating that there is no record of a specific marriage license being issued to the petitioning parties, and that the said license number was in fact issued to a different couple, is sufficient evidence to prove the absence of a valid marriage license and overcome the presumption of a valid marriage, especially when the State fails to present contrary evidence.	Persons and Family Law Family Code, Articles 2, 3, and 4
Rivera vs. Woo Namsun (23rd November 2021)	AK651650 1007 SCRA 90 , G.R. No. 248355	Maricel L. Rivera, a Filipina, married Woo Namsun, a South Korean national, in the Philippines. After moving to South Korea, their marriage deteriorated, and Woo Namsun obtained a divorce decree from the Seoul Family Court, after which he remarried. Seeking to remarry as well, Rivera filed a petition in the Philippines for the judicial recognition of the foreign divorce decree to capacitate her to contract another marriage, as required under Philippine law. The case escalated to the Supreme Court after the Court of Appeals overturned the trial court's initial grant of her petition due to deficiencies in her evidentiary submissions.	A party pleading a foreign divorce decree must prove the divorce as a fact and demonstrate its conformity to the foreign law allowing it, in accordance with Sections 24 and 25 of Rule 132 of the Rules of Court; however, in the interest of substantial justice and to uphold the purpose of Article 26 of the Family Code, the Supreme Court may remand the case for further proceedings and reception of evidence rather than dismiss it for failure to strictly comply with these evidentiary rules.	Persons and Family Law Article 26, Family Code
Pulido v. People (27th July 2021)	AK493307 995 SCRA 1 , G.R. No. 220149	The case arose from a criminal complaint for Bigamy filed by Nora S. Arcon against her husband, Luisito G. Pulido. Pulido married Arcon in 1983. While this marriage was subsisting, he married another woman, Rowena U. Baleda, in 1995. Upon discovering the second marriage in 2007, Arcon filed the bigamy charge. Pulido's defense centered on the claim that his first marriage to Arcon was void ab initio due to the absence of a valid marriage license, a fact which was later confirmed by a judicial declaration of nullity obtained while the bigamy case was ongoing.	In a criminal prosecution for bigamy, an accused can validly interpose the defense of a void ab initio marriage, and a judicial declaration of the absolute nullity of the first and/or subsequent marriage, irrespective of the time it was obtained, is a valid defense that negates the element of a prior valid and subsisting marriage.	Persons and Family Law Family Code, Article 40
Ambrose vs. Suque-Ambrose (23rd June 2021)	AK169090 988 SCRA 482 , G.R. No. 206761	The petitioner, a citizen of the United States, married the respondent, a citizen of the Philippines, in Manila. Two years later, the petitioner sought to have their marriage declared void on the ground of the respondent's psychological incapacity under Philippine law. The dispute arose when the trial court dismissed his petition not on its merits, but on the purely legal question of whether he, as a foreigner, had the standing to file such a case in a Philippine court.	A foreign national who is married in the Philippines has the legal capacity and personality to file a petition for declaration of nullity of that marriage before a Philippine court. The governing principle is _lex loci celebrationis_ (the law of the place of the ceremony), not the nationality principle under Article 15 of the Civil Code; thus, Philippine law applies to the incidents and consequences of a marriage celebrated in the Philippines, irrespective of the contracting parties' citizenship.	Persons and Family Law Article 26 and 36, Family Code; Article 15, Civil Code
National Power Corporation vs. Benguet Electric Cooperative, Inc. (14th June 2021)	AK620202 985 SCRA 198 , G.R. No. 218378	National Power Corporation (NPC), a government-owned corporation, supplied electricity to Benguet Electric Cooperative, Inc. (BENECO), a power distributor, under a franchise agreement and a formal Transition Contract for the Supply of Electricity. The contract governed the terms of power delivery, metering, and billing between the two entities. The dispute arose from a billing error at the Irisan Substation, one of the delivery points from NPC to BENECO.	The principle of unjust enrichment under Article 22 of the Civil Code is not a catch-all remedy and cannot be invoked when a valid contract exists between the parties; the provisions of the contract shall govern the parties' rights and obligations, including the remedies for breaches or errors.	Persons and Family Law Article 22, New Civil Code
Abel vs. Rule (12th May 2021)	AK212824 984 SCRA 429 , G.R. No. 234457	The case arose from a petition to recognize a foreign judgment of divorce. The petitioner, Raemark S. Abel, was a US citizen when he married Mindy P. Rule, a Filipino citizen, in California. They later jointly filed for and were granted a summary dissolution of their marriage by a California court. Subsequently, Abel reacquired his Filipino citizenship (becoming a dual citizen), while Rule became a naturalized US citizen. Abel sought to have their foreign divorce recognized in the Philippines to be able to register his subsequent marriage, but the government, through the Office of the Solicitor General, opposed it on the ground that the divorce was obtained jointly, which it argued was contrary to Philippine public policy and the text of Article 26(2) of the Family Code.	Under Article 26(2) of the Family Code, a foreign divorce decree can be judicially recognized in the Philippines regardless of who initiated the proceedings—whether it was the alien spouse, the Filipino spouse, or both spouses jointly. Once a divorce decree is issued by a competent foreign court capacitating the alien spouse to remarry, the alien spouse is deemed to have "obtained" the divorce within the meaning of the law, thereby allowing the Filipino spouse to also have the capacity to remarry under Philippine law.	Persons and Family Law Article 26(2) of the Family Code
Tan-Andal vs. Andal (11th May 2021)	AK194649 983 SCRA 28 , G.R. No. 196359	The interpretation of Article 36 of the Family Code on psychological incapacity has been historically restrictive, primarily due to the landmark cases of _Santos v. Court of Appeals_ and _Republic v. Court of Appeals and Molina_. The _Molina_ doctrine, in particular, established a set of eight stringent guidelines that courts were required to follow, including the requirement that the incapacity be medically or clinically identified, proven by experts, and shown to be grave, permanent, and incurable. This rigid framework was criticized in subsequent cases like _Ngo Te v. Yu-Te_ for being a "strait-jacket" that was inconsistent with the legislative intent of making the provision humane and resilient. The present case provided the Supreme Court with the opportunity to restate the doctrine in light of evolving science, jurisprudence, and contemporary circumstances, aiming to create a more nuanced and humane application of the law.	Psychological incapacity under Article 36 of the Family Code is a legal, not a medical, concept, and it is not a mental incapacity or a personality disorder that must be proven through expert opinion; its existence must be established by clear and convincing evidence showing a party's failure to comprehend and comply with their essential marital obligations due to a genuinely serious psychic cause that is grave, has juridical antecedence, and is incurable in a legal sense (i.e., enduring and persistent with respect to a specific partner).	Persons and Family Law Family Code, Article 36
Ado-an-Morimoto vs. Morimoto (15th March 2021)	AK452809 976 SCRA 352 , G.R. No. 247576	Sometime before December 2007, a friend introduced petitioner Rosario D. Ado-an-Morimoto to respondent Yoshio Morimoto, a Japanese national. The introduction was made for the specific purpose of arranging a simulated marriage between them, which would serve as an artifice to facilitate Rosario's acquisition of a Japanese visa. The parties agreed to this arrangement with no intention of entering into a genuine marital relationship.	A marriage that is totally simulated, where the parties have no genuine intent to enter into marital relations and merely use it as a front to obtain illicit benefits, is void ab initio for the absolute lack of the essential requisite of consent.	Persons and Family Law Family Code, Articles 2, 3, and 4
Cabasal vs. BPI Family Savings Bank, Inc. (18th November 2020)	AK197938 963 SCRA 369 , G.R. No. 233846	Petitioners Spouses Nestor and Ma. Belen Cabasal were engaged in a build-and-sell business and obtained a credit line from BPI Family Savings Bank (BPI), secured by mortgages on two real properties. After three years, they found a buyer, Eloisa Guevarra Co, who agreed to purchase the properties through a sale with assumption of mortgage. At the time of this proposed transaction, the petitioners' loan accounts with BPI were already past due. The dispute arose from the interaction between the petitioners, their buyer, and a BPI employee when they attempted to process the transaction at the bank.	An act cannot be considered an abuse of right under Article 19 of the New Civil Code unless the claimant proves by clear and convincing evidence that the act was performed in bad faith or with a malicious intent to injure; merely enforcing a company policy or being blunt in communication, without a dishonest purpose or moral obliquity, does not give rise to liability for damages.	Persons and Family Law Article 19, 20, and 21, New Civil Code
Navarro-Banaria vs. Banaria (28th July 2020)	AK776525 945 SCRA 258 , G.R. No. 217806	The respondents are the children and grandchildren of the late Pascasio S. Banaria from his previous marriage. The petitioner, Adelaida C. Navarro-Banaria, is the legal wife of Pascasio and the stepmother to his children. At the time of the events, Pascasio was elderly, frail, and suffering from physical and mental infirmities that rendered him dependent on others. The dispute arose from the respondents' efforts to celebrate their patriarch's 90th birthday, an annual family tradition, and the petitioner's alleged malicious actions that prevented his attendance and caused the respondents significant distress and financial loss.	A person's exercise of a legal right, such as a wife's prerogative in matters concerning her husband, is not absolute and must conform to the standards of conduct prescribed by Article 19 of the Civil Code; exercising such a right in bad faith, with the intent to prejudice or injure another, constitutes an abuse of right that is legally actionable and gives rise to liability for damages under Article 21 of the Civil Code.	Persons and Family Law Article 19 and 21 of the Civil Code
Kane vs. Roggenkamp (6th July 2020)	AK466674 G.R. No. 214326 , 941 SCRA 306	Alastair John Kane and Patricia Roggenkamp, both Australian citizens, were in a romantic relationship and resided together in Parañaque City, Philippines. Their relationship soured following an incident where Roggenkamp alleged that Kane physically assaulted her. This led to the filing of criminal charges against Kane for violation of R.A. 9262, with Roggenkamp as the private complainant. Kane was eventually acquitted in the criminal case, which then led Roggenkamp to file a separate civil suit for damages, sparking the procedural and substantive disputes that reached the Supreme Court.	An acquittal in a criminal case for physical violence based on reasonable doubt is not a bar to the subsequent filing of an independent civil action for damages for physical injuries under Article 33 of the Civil Code, unless the judgment of acquittal explicitly declares that the facts from which the civil liability might arise did not exist.	Persons and Family Law Article 33 of the Civil Code
Lomarda vs. Fudalan (17th June 2020)	AK894620 938 SCRA 613 , G.R. No. 246012	Respondent Engr. Elmer Fudalan applied for electrical service from Bohol I Electric Cooperative, Inc. (BOHECO I) for his farmhouse. The process required him to hire a BOHECO I-authorized electrician and secure a certification from the local Barangay Power Association (BAPA), which was chaired by petitioner Crispina Raso. The dispute arose from the petitioners' actions following the respondent's attempt to comply with these requirements.	The exercise of a legal right, such as enforcing the rules of an electric cooperative, becomes an actionable tort under Articles 19 and 21 of the Civil Code if it is done in a manner contrary to morals and good customs, with the intent to injure another; such an abuse of rights warrants the award of damages to the aggrieved party.	Persons and Family Law
Galapon vs. Republic (22nd January 2020)	AK051471 930 SCRA 51 , G.R. No. 243722	Cynthia A. Galapon, a Filipina, and Noh Shik Park, a South Korean national, were married in the Philippines in 2012. Their relationship deteriorated, and they subsequently obtained a divorce by mutual agreement in South Korea, which was confirmed by the Cheongju Local Court. Following the divorce, Galapon sought to have the foreign divorce decree recognized in the Philippines to regain her capacity to remarry.	Article 26, paragraph 2 of the Family Code allows for the recognition of a foreign divorce decree in the Philippines regardless of whether the divorce was obtained solely by the foreign spouse, solely by the Filipino spouse, or jointly by both spouses. The purpose of the provision is to avoid the unjust situation where the Filipino spouse is still considered married under Philippine law while the foreign spouse is free to remarry under their own national law.	Persons and Family Law
In Re: Petition for Judicial Recognition of Divorce Between Minuro Takahashi and Juliet Rendora Moraña (5th December 2019)	AK060710 927 SCRA 265 , G.R. No. 227605	Petitioner Juliet Rendora Moraña, a Filipino, married Minoru Takahashi, a Japanese national, in the Philippines in 2002. They lived in Japan and had two children. After ten years, the couple became estranged, with the petitioner alleging that her husband failed to provide support and started cohabiting with another woman. Her husband suggested they obtain a divorce so that their children could receive financial assistance from the Japanese government. Believing it was for their children's welfare, the petitioner agreed, and they jointly applied for and were granted a divorce by the Office of the Mayor of Fukuyama City, Japan.	A foreign divorce decree, even if obtained jointly by the Filipino and alien spouses or initiated by the Filipino spouse alone, is recognizable in the Philippines for the purpose of capacitating the Filipino spouse to remarry, pursuant to the second paragraph of Article 26 of the Family Code; however, both the fact of the divorce and the national law of the alien spouse allowing the divorce must be proven as facts in accordance with the Rules on Evidence.	Persons and Family Law
Arreza vs. Toyo (1st July 2019)	AK116312 906 SCRA 588 , G.R. No. 213198	Genevieve Rosal Arreza, a Filipino citizen, and Tetsushi Toyo, a Japanese citizen, were married in the Philippines. After 19 years of marriage, they jointly obtained a divorce by agreement in Japan. Subsequently, Genevieve filed a petition in a Philippine Regional Trial Court to have the foreign divorce recognized and to be declared capacitated to remarry under Article 26 of the Family Code. The core of the legal dispute arose from the trial court's assessment of the evidence presented to prove the existence and validity of the Japanese law that served as the basis for the divorce.	Foreign judgments and laws are not subject to judicial notice by Philippine courts and must be pleaded and proven as facts in accordance with the Rules of Evidence, specifically Rule 132, Sections 24 and 25, before their legal effects can be recognized and extended to a Filipino spouse.	Persons and Family Law
Racho vs. Tanaka (25th June 2018)	AK473109 868 SCRA 25 , G.R. No. 199515	Rhodora Racho, a Filipina, married Seiichi Tanaka, a Japanese national, in the Philippines. After nine years of living together in Japan, they obtained a divorce by agreement according to Japanese law. To be able to remarry, Racho needed to have the foreign divorce recognized in the Philippines to have it annotated on her Certificate of Marriage. However, her attempts to register the divorce with Philippine authorities were unsuccessful without a court order, prompting her to file a petition for judicial recognition.	A foreign divorce can be judicially recognized in the Philippines regardless of which spouse initiated the proceeding, including divorces obtained by mutual agreement, as long as it is proven that the divorce was validly obtained according to the national law of the foreign spouse and that said law allows for the absolute dissolution of the marriage. A duly authenticated Certificate of Acceptance of the Report of Divorce is sufficient and admissible proof of the fact of a foreign divorce.	Persons and Family Law
Republic vs. Manalo (24th April 2018)	AK627716 862 SCRA 580 , G.R. No. 221029	Philippine law, under the nationality principle of Article 15 of the Civil Code, does not permit absolute divorce for its citizens. However, Article 26, Paragraph 2 of the Family Code provides an exception for a Filipino spouse married to a foreigner. Historically, this exception was strictly interpreted to apply only when the foreign spouse initiated and obtained the divorce. This case arose from the need to address the "absurd situation" where a Filipino remains married to a foreign ex-spouse who, by virtue of a foreign divorce, is no longer married to the Filipino and is free to remarry.	A foreign divorce decree, whether initiated by the Filipino or the alien spouse, is recognizable in the Philippines, provided it was validly obtained abroad by the alien spouse capacitating him or her to remarry; the Filipino spouse shall likewise have the capacity to remarry under Philippine law.	Legal Research and Writing Persons and Family Law
Tilar vs. Tilar (12th July 2017)	AK872417 831 SCRA 116 , G.R. No. 214529	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.	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.	Persons and Family Law
Coca-Cola Bottlers Philippines, Inc. vs. Bernardo (7th November 2016)	AK790851 807 SCRA 29 , G.R. No. 190667	The dispute arose from a long-standing business relationship between petitioner Coca-Cola Bottlers Philippines, Inc. (CCBPI), a large-scale beverage manufacturer, and respondents Spouses Bernardo, who operated "Jolly Beverage Enterprises" as a wholesaler and exclusive distributor of CCBPI's products in certain areas of Quezon City since 1987. Their partnership, formalized through exclusive dealership agreements, deteriorated when CCBPI, towards the end of their last contract, implemented strategic actions that the respondents claimed were aimed at eliminating them as a competitor and taking over their established customer base.	A manufacturer that employs deceit, oppression, and high-handed business methods to unjustly take over the market of its own distributor, such as by using a customer list obtained through a false promise and implementing discriminatory pricing schemes, is liable for damages under the principles of abuse of rights (Articles 19, 20, and 21) and unfair competition (Article 28) of the Civil Code.	Persons and Family Law Article 19, 20, 21, and 28, Civil Code
Kalaw vs. Fernandez (14th January 2015)	AK745229 745 SCRA 512 , G.R. No. 166357	Valerio E. Kalaw (petitioner) and Ma. Elena Fernandez (respondent) were married on November 4, 1976. The petitioner filed a complaint to declare their marriage null and void on the ground of respondent's psychological incapacity. He alleged that her constant mahjong sessions, neglect of their children, infidelity, and obsessive need for attention were manifestations of a Narcissistic Personality Disorder that rendered her incapable of performing her essential marital duties. The respondent denied these allegations and countered that it was the petitioner who was psychologically incapacitated.	The determination of psychological incapacity under Article 36 of the Family Code should be based on the totality of evidence presented in each case, and courts must consider expert opinions as decisive evidence, even without a personal examination of the subject, provided the opinion is based on verifiable facts on record. A rigid and overly strict application of the Molina guidelines should be avoided, as the concept of psychological incapacity is not meant to be a "strait-jacket" but should be applied with resiliency to give a "decent burial to a stillborn marriage." Psychological incapacity may be proven to exist in either or both spouses, and if established, justifies the declaration of the marriage as null and void.	Persons and Family Law Article 36 of the Family Code
Araullo vs. Aquino (1st July 2014)	AK306263 728 SCRA 1 , 737 Phil. 457 , G.R. No. 209287 , G.R. NO. 209135 , G.R. NO. 209136 , G.R. NO. 209155 , G.R. NO. 209164 , G.R. NO. 209260 , G.R. NO. 209442 , G.R. NO. 209517 , G.R. NO. 209569	The Disbursement Acceleration Program (DAP) was a mechanism introduced by the Department of Budget and Management (DBM) under Secretary Florencio Abad. It allowed the executive branch to pool savings from various government agencies and realign them to other projects to accelerate economic growth. However, petitioners argued that it violated the constitutional power of Congress over appropriations.	The Supreme Court issued a ruling declaring several aspects of the DAP (Disbursement Acceleration Program) unconstitutional, including: the withdrawal of unobligated allotments and their designation as savings before the fiscal year's end, the cross-border transfers of savings to offices outside the Executive branch, and the use of savings to fund programs, activities, or projects not covered by the GAA (General Appropriations Act). In applying the Operative Fact Doctrine, the Court established that while projects already implemented under the DAP in good faith would remain intact, the officials responsible for these actions could still be held accountable.	Constitutional Law I Persons and Family Law Philosophy of Law Statutory Construction
Capili vs. People (3rd July 2013)	AK509180 G.R. No. 183805 , 700 SCRA 443	Petitioner James Walter P. Capili was legally married to Karla Y. Medina-Capili. During the subsistence of this first marriage, he contracted a second marriage with private respondent Shirley G. Tismo. This led to the filing of a criminal information for bigamy against him. Subsequently, a separate civil case was initiated, which resulted in the judicial declaration of the second marriage as null and void. The petitioner then sought the dismissal of the bigamy charge, arguing that the nullity of the second marriage removed the basis for the criminal case.	A subsequent judicial declaration of nullity of a second marriage is not a valid defense against a charge of bigamy, as the crime is consummated at the time the second marriage is contracted during the subsistence of a prior valid marriage.	Persons and Family Law Prejudicial Question
Hing vs. Choachuy (26th June 2013)	AK967276 699 SCRA 667 , G.R. No. 179736	Petitioners Spouses Hing and respondents Choachuy are owners of adjacent commercial lots in Mandaue City, Cebu. The respondents operate an auto-repair shop, Aldo Goodyear Servitec, on their property. A prior legal dispute existed between the parties, initiated by the respondents' company (Aldo) against the petitioners concerning the construction of a fence. Following this, the respondents installed two video surveillance cameras on their building, which were directed at the petitioners' property. Petitioners alleged that this was an illegal act of surveillance intended to gather evidence for the prior case and was a violation of their privacy, prompting them to file the present case for injunction and damages.	The right to privacy under Article 26(1) of the Civil Code, which prohibits "prying into the privacy of another's residence," is not strictly confined to residential properties; it also protects areas like business offices where the public is excluded and where an individual has a reasonable expectation of privacy.	Persons and Family Law Article 26(1) of the Civil Code
Fujiki vs. Marinay (26th June 2013)	AK267379 700 SCRA 69 , G.R. No. 196049	Petitioner Minoru Fujiki, a Japanese national, married respondent Maria Paz Marinay, a Filipino, in the Philippines in 2004. Due to family objections, they lived separately and eventually lost contact. In 2008, Marinay, without dissolving her first marriage, married another Japanese national, Shinichi Maekara, in Quezon City. After allegedly suffering abuse from Maekara, Marinay reconnected with Fujiki in Japan. In 2010, with Fujiki's help, Marinay obtained a judgment from a Japanese family court declaring her marriage to Maekara void on the ground of bigamy. Fujiki then sought to have this foreign judgment recognized in the Philippines to nullify the bigamous marriage under Philippine law and to correct the civil registry.	A petition to recognize a foreign judgment relating to marital status does not require a re-litigation of the case but only proof of the judgment as a fact under the Rules of Court; it is a special proceeding, not a civil action for declaration of nullity governed by A.M. No. 02-11-10-SC, and the spouse of the prior subsisting marriage has the legal personality to file such a petition.	Persons and Family Law Article 15, Civil Code
Nagkakaisang Maralita ng Sitio Masigasig, Inc. vs. Military Shrine Services-Philippine Veterans Affairs Office, Department of National Defense (5th June 2013)	AK977863 697 SCRA 359 , G.R. No. 187587	The dispute originates from the status of land within the Fort Bonifacio military reservation. In 1957, President Carlos P. Garcia reserved the area for military use through Proclamation No. 423. Over the years, subsequent proclamations excluded certain portions for other purposes. In 1986, President Ferdinand E. Marcos issued Proclamation No. 2476, declaring specific barangays within the reservation as alienable and disposable. The core of the controversy is a handwritten note he allegedly added to this proclamation to include Western Bicutan, which was omitted from the official publication, leading petitioners to claim rights over the land they occupy therein.	An unpublished portion of a law, such as a handwritten addendum to a presidential proclamation, has no legal force or effect; publication in full is an indispensable condition for the effectivity of all laws to ensure the public is duly informed of their contents and to comply with the due process requirement.	Persons and Family Law Article 2 and 8, Civil Code
Hacienda Luisita, Inc. vs. Presidential Agrarian Reform Council, et al. (24th April 2012)	AK280291 686 Phil. 377 , G.R. No. 171101	The case revolves around the implementation of the Comprehensive Agrarian Reform Program (CARP) in Hacienda Luisita, a large sugar plantation. Instead of direct land distribution, HLI implemented a Stock Distribution Plan (SDP) in 1989, approved by the Presidential Agrarian Reform Council (PARC). Years later, PARC revoked the SDP, leading to legal challenges by HLI. The Supreme Court initially affirmed PARC's revocation but allowed FWBs the option to remain HLI stockholders. Subsequent motions led to the revocation of this option and clarifications on just compensation and the distribution of proceeds from land sales, which are further addressed in this resolution.	The date of "taking" of Hacienda Luisita's agricultural lands for agrarian reform purposes is November 21, 1989, the date PARC approved HLI's Stock Distribution Plan (SDP); the option previously granted to FWBs to remain HLI stockholders is revoked, and control over agricultural lands must be in the hands of the farmers; the FWBs are entitled to the proceeds from the sale of converted lands (less specified deductions); and HLI is entitled to just compensation from the government for the homelots distributed to the FWBs.	Constitutional Law I Persons and Family Law
Land Bank of the Philippines vs. Ong (24th November 2010)	AK275684 636 SCRA 266 , G.R. No. 190755	On March 18, 1996, the Spouses Johnson and Evangeline Sy obtained a PhP 16 million loan from Land Bank, secured by three residential lots, five cargo trucks, and a warehouse. The loan agreement included an acceleration clause. When the Spouses Sy found themselves unable to service the loan, they sought to transfer their obligation.	A bank that accepts a conditional payment from a third person for the assumption of a mortgage, and subsequently disapproves the application without notice while retaining the payment, is obligated to return the amount under the principle of unjust enrichment, as it has no legal ground to keep the money.	Persons and Family Law Article 19 and 22 of the Civil Code
Yuchengco vs. Manila Chronicle Publishing Corporation (25th November 2009)	AK525473 605 SCRA 684 , G.R. No. 184315	The case arose from a business rivalry between petitioner Alfonso T. Yuchengco and respondent Roberto Coyiuto, Jr., particularly concerning their competing interests for control over Oriental Petroleum Mineral Corporation. In the months leading up to a crucial stockholders' meeting for Oriental, a series of articles critical of Yuchengco were published in The Manila Chronicle, a newspaper owned and controlled by Coyiuto. These articles formed the basis of Yuchengco's civil complaint for damages due to libel.	When actual malice (malice in fact) is proven, the defense that libelous articles are qualifiedly privileged communications becomes futile, as such a defense merely negates the legal presumption of malice (malice in law) but does not overcome proven actual malice.	Persons and Family Law Article 33, Civil Code
Dreamwork Construction, Inc. vs. Janiola (30th June 2009)	AK886351 G.R. No. 184861 , 591 SCRA 466	The legal dispute originated from a construction agreement between petitioner Dreamwork Construction, Inc. and private respondent Cleofe S. Janiola. In connection with this agreement, Janiola issued several checks to Dreamwork. When these checks were dishonored, Dreamwork initiated criminal proceedings against Janiola for violation of the Bouncing Checks Law (BP 22). Subsequently, Janiola filed a separate civil action seeking to rescind the construction agreement, which then became the basis for her motion to suspend the ongoing criminal case.	For a prejudicial question to exist, Section 7, Rule 111 of the 2000 Rules on Criminal Procedure explicitly requires that the civil action be "previously instituted" before the "subsequent criminal action"; additionally, the resolution of a civil case for rescission of contract is not determinative of guilt in a criminal case for violation of BP 22, as the gravamen of the latter offense is the mere act of issuing a worthless check.	Persons and Family Law Article 36 of the Civil Code
Lazatin vs. Desierto (5th June 2009)	AK190398 588 SCRA 285 , G.R. No. 147097	The case originated from a complaint-affidavit filed by the Fact-Finding and Intelligence Bureau of the Office of the Ombudsman against then Congressman Carmelo F. Lazatin and his co-petitioners. The complaint alleged irregularities in the use of Lazatin's Countrywide Development Fund (CDF) for 1996, where he was accused of being both the proponent and implementer of projects, signing disbursement vouchers, and receiving checks as claimant, effectively converting public funds into cash.	The Ombudsman possesses prosecutorial powers and exercises supervision and control over the Office of the Special Prosecutor (OSP) as constitutionally sanctioned by Congress through Republic Act No. 6770; consequently, the Ombudsman has the authority to approve, disapprove, or overturn any resolution issued by the OSP.	Persons and Family Law Civil Code, Article 8
Ngo Te vs. Yu-Te (13th February 2009)	AK804453 579 SCRA 193 , G.R. No. 161793	The case arose from the brief and volatile relationship between petitioner Edward Kenneth Ngo Te and respondent Rowena Ong Gutierrez Yu-Te, who were college students when they met in 1996. Their relationship, founded on shared angst towards their families, quickly escalated into an elopement initiated by Rowena. This was followed by a forced marriage under threatening circumstances orchestrated by Rowena's uncle. The marriage lasted only a few months before the couple parted ways, leading Edward to seek a declaration of nullity nearly four years later on the grounds of psychological incapacity.	A marriage is void under Article 36 of the Family Code when expert psychological testimony and the totality of evidence establish that one or both parties suffer from a grave, severe, and incurable personality disorder that renders them truly incapable of assuming the essential obligations of marriage. The strict guidelines established in _Republic v. Molina_ should not be applied as a rigid "strait-jacket" but must be interpreted with a view towards the law's intent for a case-by-case analysis, where the findings of the trial court and the opinion of psychological experts are given decisive weight.	Persons and Family Law Article 36 of the Family Code
Garcillano vs. The House of Representatives Committees on Public Information, et al. (23rd December 2008)	AK185298 595 Phil. 775 , G.R. No. 170338 , G.R. No. 179275	The "Hello Garci" tapes, allegedly containing a wiretapped conversation between then-President Gloria Macapagal-Arroyo and COMELEC Commissioner Virgilio Garcillano discussing the manipulation of the 2004 presidential election results, surfaced and caused a major political controversy. Both Houses of Congress initiated separate legislative inquiries into the matter, leading to the petitions filed in this case.	The Senate or its committees may conduct inquiries in aid of legislation only in accordance with duly published rules of procedure; publication of such rules is mandatory for each Congress and failure to do so renders any such inquiry procedurally infirm and unconstitutional.	Constitutional Law I Constitutional Law II Persons and Family Law Civil Code, Article 2
Republic vs. Cagandahan (12th September 2008)	AK425333 G.R. No. 166676 , 565 SCRA 72	The case arose from the unique situation of Jennifer Cagandahan, who was born with Congenital Adrenal Hyperplasia (CAH), a condition that causes a person with female chromosomes (XX) to develop ambiguous genitalia and secondary male characteristics due to excessive production of male hormones. Despite being registered as female at birth, Cagandahan's physical development and self-perception aligned with the male gender, prompting her to seek legal recognition of her identity by petitioning to correct her birth certificate.	Where a person is biologically or naturally intersex, the determining factor in their gender classification for legal and civil registry purposes is what the individual, having reached the age of majority, reasonably thinks of their own sex, supported by medical evidence of their condition.	Persons and Family Law
Mata vs. Agravante (6th August 2008)	AK929535 561 SCRA 66 , G.R. No. 147597	The dispute originated from a labor issue where former security guards of the Bessang Pass Security Agency, the respondents, filed complaints against their employer, the petitioner, for non-payment of salaries and other benefits. To pursue their claims, they not only filed a case with the National Labor Relations Commission (NLRC) but also sought the cancellation of the agency's license from the Philippine National Police (PNP), sending copies of their complaint to multiple government bodies.	The exercise of a legal right, such as filing complaints with appropriate government agencies to seek redress for grievances, does not give rise to liability for damages unless it is proven that such an act was done with malice or bad faith and with the intent to injure another, in violation of the principle of abuse of rights under Articles 19 and 21 of the Civil Code.	Persons and Family Law Article 19, 20, and 21, Civil Code
Bier vs. Bier, 547 SCRA 123 (27th February 2008)	AK808895 547 SCRA 123 , G.R. No. 173294	Petitioner Renne Enrique Bier, an electronics technician based in Saudi Arabia, and respondent Ma. Lourdes A. Bier married after a six-month long-distance courtship. For the first three years of their marriage, the relationship was positive, with the respondent described as a sweet, loving, and caring wife. The couple maintained residences in both the Philippines and Saudi Arabia, shuttling between the two countries to spend time together. However, after three years, the respondent's behavior allegedly changed drastically, leading to the eventual breakdown of the marriage and her departure for the United States, prompting the petitioner to file for nullity.	A petition for declaration of nullity of marriage based on psychological incapacity under Article 36 of the Family Code requires clear and convincing proof of the gravity, juridical antecedence, and incurability of the alleged incapacity; failure to establish these three essential characteristics, especially the root cause of the disorder and its existence at the inception of the marriage, is fatal to the petition, even if the party's post-marital behavior is shown to be irresponsible or neglectful.	Persons and Family Law Article 36 of the Family Code
Silverio vs. Republic (19th October 2007)	AK402555 537 SCRA 373 , G.R. No. 174689	Petitioner Rommel Silverio, born anatomically male, identified as a female from childhood and felt "trapped in a man's body." After consulting with doctors, he underwent hormone therapy, breast augmentation, and ultimately, a sex reassignment surgery in Thailand. Living as a female and engaged to be married to a man, he sought to have his public records, specifically his birth certificate, reflect his new identity and physical state by changing his first name and sex entry.	Philippine law does not permit a person who has undergone sex reassignment surgery to change their name and sex as recorded in their birth certificate to align with their new physical characteristics, as there is no statute that recognizes or governs the effects of such a procedure.	Persons and Family Law Family Code, Articles 1 and 2
Commissioner of Internal Revenue vs. Primetown Property Group, Inc. (28th August 2007)	AK150634 531 SCRA 436 , G.R. No. 162155	The case originated from a claim for a tax refund by Primetown Property Group, Inc. (Primetown) for taxes paid in 1997. Due to the Asian Financial Crisis, the real estate industry slowed down, causing Primetown to suffer significant losses for that year. Despite these losses, the company had paid quarterly corporate income taxes and remitted creditable withholding taxes. Believing it was not liable for income tax due to its net loss, Primetown filed an administrative claim for a refund with the Bureau of Internal Revenue (BIR), which was not acted upon, prompting the company to seek judicial relief.	A "year" for the purpose of computing legal periods is understood to be twelve calendar months, as provided in Section 31, Chapter VIII, Book I of the Administrative Code of 1987, which has impliedly repealed the definition of a "year" as 365 days under Article 13 of the Civil Code.	Persons and Family Law Statutory Construction Article 13, Civil Code
Republic vs. Lacap (2nd March 2007)	AK609364 G.R. No. 158253 , 517 SCRA 255	The District Engineer of Pampanga initiated a public bidding for the concreting of Sitio 5 Bahay Pare. Carlito Lacap, doing business as Carwin Construction and Construction Supply, was one of three pre-qualified contractors. After submitting the lowest bid, Lacap was awarded the contract by the Department of Public Works and Highways (DPWH). A formal Contract Agreement was executed, and Lacap proceeded with and completed the project. The dispute arose when the government, through the DPWH, refused to release the payment for the completed project upon the disapproval of the District Auditor of the Commission on Audit (COA).	A contractor with an expired license who fully completes a government project is entitled to payment, as the Contractor's License Law (R.A. No. 4566) does not declare contracts entered into under such circumstances as void. The government cannot refuse payment and retain the benefits of the completed work, as this would constitute unjust enrichment under Article 22 of the Civil Code.	Persons and Family Law Article 22 of the Civil Code
Antonio vs. Reyes (10th March 2006)	AK471421 484 SCRA 353 , G.R. No. 155800	Petitioner Leonilo Antonio and respondent Marie Ivonne Reyes met in August 1989 and married in 1990. Their union produced a child who died five months after birth. The couple's relationship quickly deteriorated due to what the petitioner described as the respondent's unusual and deceitful behavior. After a brief separation and a failed attempt at reconciliation, the petitioner left the respondent for good in November 1991. This led him to file a petition for nullity of marriage, claiming that the respondent's constant and elaborate fabrications about her life were manifestations of a deep-seated psychological incapacity to assume the fundamental duties of marriage.	A party's pathological inability to abide by the truth, manifesting as a persistent and constant pattern of fabricating stories about one's self, occupation, and background, is a psychological incapacity that renders one incognitive of the essential marital obligations of mutual trust, respect, and fidelity, and thus constitutes a valid ground for the declaration of nullity of marriage under Article 36 of the Family Code.	Persons and Family Law Article 36, Family Code
Radio Communications of the Philippines, Inc. vs. Verchez (31st January 2006)	AK180962 481 SCRA 384 , G.R. No. 164349	On January 21, 1991, Editha Hebron Verchez was confined at the Sorsogon Provincial Hospital. Her daughter, Grace Verchez-Infante, sent an urgent telegram through RCPI to her sister, Zenaida Verchez-Catibog, in Quezon City, with the message "Send check money Mommy hospital." The purpose was to secure immediate financial aid for their mother's medical needs. The failure to receive a timely response caused distress and confusion within the family, leading them to believe Zenaida was ignoring their plea for help.	A telecommunications company that fails to deliver a telegram promptly due to its own negligence is liable for damages; its liability is based on _culpa contractual_ to the sender and quasi-delict to the intended recipient and other affected family members. Gross negligence in the performance of its contractual obligation, such as an inordinate delay without notifying the sender, amounts to bad faith and justifies the award of moral damages.	Persons and Family Law Article 26, New Civil Code
Republic vs. Orbecido III (5th October 2005)	AK557171 G.R. No. 154380 , 472 SCRA 114	The case arose from a legal ambiguity concerning the application of Article 26, Paragraph 2 of the Family Code. The provision's text appears to apply only to "mixed marriages" (between a Filipino and a foreigner at the time of celebration). This case presented a situation of first impression where a marriage was initially between two Filipino citizens, but one party later acquired foreign citizenship and obtained a divorce, raising the question of whether the remaining Filipino spouse was still bound by the marital tie under Philippine law.	Paragraph 2 of Article 26 of the Family Code, which capacitates a Filipino spouse to remarry after their alien spouse obtains a valid divorce abroad, applies even if both parties were Filipino citizens at the time of marriage, provided that one spouse later becomes a naturalized foreign citizen and then secures the divorce decree; the reckoning point for the application of the provision is the citizenship of the parties at the time the valid divorce is obtained.	Persons and Family Law