G.R. No. 204494 , July 27, 2016
JO-ANN DIAZ-SALGADO and husband DR. GERARD C. SALGADO, Petitioners vs. LUIS G. ANSON, Respondent

FACTS

Luis Anson filed a complaint seeking the annulment of three Unilateral Deeds of Sale executed by his late wife, Severina de Asis, in favor of her daughter Jo-Ann Diaz-Salgado, and a Deed of Extra-Judicial Settlement executed by their daughter Maria Luisa. Luis claimed he was the surviving spouse of Severina, having married her in 1966, and that the subject properties were conjugal. He alleged Severina and Maria Luisa disposed of these properties without his knowledge and consent, thereby depriving him of his share in the conjugal partnership and his inheritance as a compulsory heir.
In defense, the Spouses Salgado and Spouses Maya asserted that Luis and Severina were never legally married but were merely in a common-law relationship, which they formally terminated through a Partition Agreement in 1980. They contended the properties sold to Jo-Ann were Severina’s exclusive properties, as evidenced by titles in her name alone describing her as “single.” They further presented a Certificate of No Record of Marriage and challenged the validity of the marriage contract for lacking a marriage license. After Luis presented his evidence, the defendants filed demurrers to evidence, which the trial court initially denied.

ISSUE

The core issue is whether a valid marriage existed between Luis and Severina, which would establish the subject properties as conjugal and require Luis’s consent for their disposition.

RULING

The Supreme Court ruled in favor of Luis Anson, declaring the marriage valid and the subject properties conjugal. The legal logic proceeds from the presumption of validity accorded to marriages. The Court emphasized that the absence of a marriage license does not automatically render a marriage void, but merely voidable. For a marriage to be declared void from the beginning due to the absence of a license, such absence must be apparent on the face of the marriage contract or proven as a fact. Here, the marriage contract presented by Luis did not indicate a missing license; the space for the license number was simply left blank. The petitioners failed to present clear and convincing evidence to overcome the presumption of the marriage’s regularity. The Court also found the Partition Agreement, which described the parties as single, insufficient to prove the marriage’s nullity, as it is a mere private document that cannot prevail over a public document like a marriage contract. Consequently, the properties acquired during the union are presumed conjugal. The unilateral sale by Severina of conjugal properties without Luis’s consent is void. The Extra-Judicial Settlement executed by Maria Luisa, which excluded Luis, is likewise invalid as it infringed upon his rights as a surviving spouse and compulsory heir. The CA decision was affirmed.