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Valdes vs. RTC

The Supreme Court case Valdes vs RTC addresses the annulment of a marriage due to mutual psychological incapacity, ruling that property relations in a void marriage are governed by co-ownership rules. The court emphasized that any property acquired during the marriage is presumed to be obtained through joint efforts, even if one party did not directly participate in its acquisition. Additionally, the decision highlights that third parties are not affected by the annulment unless properly recorded in civil registries.

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Maria Carmel Acojedo
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9 views1 page

Valdes vs. RTC

The Supreme Court case Valdes vs RTC addresses the annulment of a marriage due to mutual psychological incapacity, ruling that property relations in a void marriage are governed by co-ownership rules. The court emphasized that any property acquired during the marriage is presumed to be obtained through joint efforts, even if one party did not directly participate in its acquisition. Additionally, the decision highlights that third parties are not affected by the annulment unless properly recorded in civil registries.

Uploaded by

Maria Carmel Acojedo
Copyright
© All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd

Valdes vs RTC

260 SCRA 221

Art. 52. The judgement of annulment or of absolute nullity of the marriage, the partition
and distribution of the properties of the spouses, and the delivery of the children’s
presumptive legitimes shall be recorded in the appropriate civil registry and registries of
property; otherwise, the same shall not affect third persons.

COMMENT:
Who are not affected?
Under the Rule provided for under Article 52, third parties shall NOT be affected.

FACTS:

Antonio Valdez and Consuelo Gomez were married in 1971 and begotten 5 children.
Valdez filed a petition in 1992 for a declaration of nullity of their marriage pursuant to
Article 36 of the Family Code, which was granted hence, marriage is null and void on the
ground of their mutual psychological incapacity. Stella and Joaquin are placed under the
custody of their mother while the other 3 siblings are free to choose which they prefer.

*Art. 36. A marriage contracted by any party who, at the time of the celebration, was
psychologically incapacitated to comply with the essential marital obligations of
marriage, shall likewise be void even if such incapacity becomes manifest only after its
solemnization. (As amended by E.O. No.227, dated July 17, 1987)

Gomez sought a clarification of that portion in the decision regarding the procedure for
the liquidation of common property in “unions without marriage”. During the hearing on
the motion, the children filed a joint affidavit expressing a desire to stay with their father.

HELD:

The Supreme Court ruled that in a void marriage, regardless of the cause thereof, the
property relations of the parties are governed by the rules on co-ownership. Any
property acquired during the union is prima facie presumed to have been obtained
through their joint efforts. A party who did not participate in the acquisition of the
property shall be considered as having contributed thereto jointly if said party’s efforts
consisted in the care and maintenance of the family.

*prima facie- based on the first impression; accepted as correct until proved otherwise

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