GR L 3474; (September, 1907) (Digest)
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G.R. No. L-3474
FACTS:
Plaintiffs sought to annul a deed of real estate executed by Antonio Enriquez in favor of defendant Carmen de la Cavada. The lower court found that the property was acquired by Antonio Enriquez in 1861, during his marriage to Doña Ciriaca Villanueva. The court further held that upon Doña Ciriaca’s death in 1882, her heirs (the plaintiffs) inherited an undivided half of the property, and Antonio Enriquez’s subsequent conveyance of the entire property in 1883 was only effective as to his half. The lower court’s reasoning hinged on the presumption that Antonio Enriquez and Doña Ciriaca Villanueva were legally married prior to 1861, based on evidence that they lived together as husband and wife and had children baptized as legitimate prior to a formal marriage ceremony in 1865. The defendants appealed this decision.
ISSUE:
Whether or not the cohabitation of Antonio Enriquez and Doña Ciriaca Villanueva, prior to their 1865 marriage ceremony, along with the baptism of their children as legitimate, constituted sufficient evidence of a legal marriage prior to 1861 under the laws then in force in the Islands.
RULING:
No. The Supreme Court held that under the laws in force in the Philippine Islands during the Spanish domination, a valid marriage could not be contracted by mere agreement or cohabitation, but required the intervention of an ecclesiastical or civil functionary. The Court found no proof of a marriage ceremony, with the intervention of an ecclesiastical functionary, being celebrated between Antonio Enriquez and Doña Ciriaca Villanueva prior to 1865. The fact that they lived together as husband and wife and had children baptized as legitimate prior to the 1865 ceremony was deemed insufficient evidence to prove a prior legal marriage. Consequently, the property acquired by Antonio Enriquez in 1861 was not part of the conjugal partnership but was his separate capital. Upon Doña Ciriaca’s death, her heirs inherited no interest in the property. The judgment of the lower court was reversed.