Sunday, June 26, 2016

Lecture 2

CIVIL LAW REVIEW I LECTURE SERIES
Articles 37 to 51, New Civil Code
            Articles 1 to 26, Family Code of the Philippines
For: University of San Agustin School of Law
General Luna Street, Iloilo City
SY 2016-2017, 1st Semester
By: Atty. Eduardo T. Reyes, III


Article 37.

II. Juridical Capacity v. Capacity to Act

Juridical Capacity- the FITNESS to be the subject of legal relations, is inherent in every natural person and is lost only through death.

Capacity to Act- which is the POWER to do acts with legal effect, is acquired and may be lost.

Restrictions on Capacity to Act.

1)     Minority
2)    Insanity or imbecility
3)    The state of being a deaf-mute;
4)   Prodigality; and,
5)    Civil Interdiction

Circumstances that MODIFY or LIMIT Capacity to Act

1)     Age
2)    Insanity
3)    Imbecility
4)   The state of being a deaf-mute
5)    Penalty
6)   Prodigality
7)    Family relations
8)   Alienage
9)   Absence
10) Insolvency; and
11)  Trusteeship

PERSONS

Natural Persons. Birth determines personality.
Exception: Presumptive personality. A conceived child shall be considered born for all purposes that are favorable to it provided it be born alive.

For civil purposes, the fetus (with intra-uterine life of at least seven months) is considered born if it is alive at the time it is completely delivered from the mother’s womb.

However, if the fetus had an intra-uterine life of less than seven months- it is not deemed born if it dies within twenty-four hours after its complete delivery from the maternal womb.

BAR QUESTION (1999)- A donation is made in favor of a fetus inside the mother’s womb. Is the donation valid? Discuss.

-         Quimiguing v. Icao, 34 SCRA 132- Suit was filed for support of an unborn child which resulted from seduction.


NEW FAMILY CODE (R.A. No. 6809, December 18, 1989).

Article 1. Marriage is a special contract of permanent union between a man and a woman entered into in accordance with the law for the establishment of conjugal and family life. It is the foundation of the family and an inviolable social institution whose nature, consequences, and incidents are governed by law and not subject to stipulation, except that marriage settlements may fix the property relations during the marriage within the limits provided by this Code.

-        No union is more profound than marriage, for it embodies the highest ideals of love, fidelity, devotion, and family. In forming a marital union, two people become something greater than once they were.”(Justice Anthony Kennedy (On Decision upholding same-sex marriage in the United States).

·       Marriage as a civil contract
·       Petitioner filed for annulment of marriage on ground of “failure of consideration” because he only wanted to give a name to the child in respondent’s womb, which however was never born.
·        “It is not possible to have a marriage for one purpose and no marriage at all for other purposes, for marriage is not only a contract but a status and a kind of fealty to the State as well x x x”.[1]
·       Thus, rules governing rescission of civil contracts do not obtain in the annulment of marriage conundrum
·       The reservations kept in the deep recesses of the heart of the spouse at the time of entering into marriage are of no consequence for as long as he knows that what he is entering into is a  marriage
·       Art. 1351, NCC- “The particular motives of the parties in entering into a contract are different from the cause thereof”.

·       Marriage in jest v. Marriage for financial consideration
·       Republic v. Albios[2]. “limited-purpose marriage”. Marriage for convenience. For Immigration purposes
·       “Motives for entering into a marriage are varied and complex. The State does not and cannot dictate on the kind of life that a couple chooses to lead. Any attempt to regulate their lifestyle would go into the realm of their right to privacy and would raise serious constitutional questions. The right to marital privacy allows married couples to structure their marriages in almost any way they see fit, to live together or live apart, to have children or no children, to love one another or not, and so on. Thus, marriages entered into for other purposes, limited or otherwise, such as convenience, companionship. Money, status and title provided that they comply with all the legal requisites are equally valid. Love, though the ideal consideration in a marriage contract, is not the only valid cause for marriage.    

Marriage is insulated against:

Ø Discriminatory policies such as: (1)terminating a female employee who contracts marriage (PT&T v. NLRC, 272 SCRA 596) (2) PAL cases on female flight attendants becoming pregnant

Ø Jealous wife rummages through office files of husband and discovers damning evidence of infidelity. (Zulueta v. Court of Appeals, 253SCRA 699).

Ø BUT, is there something in the Constitution that prohibits Absolute divorce?

Ø In Sta. Barbara, California, USA, a website was put-up for struggling college students who can barely make it through college where they could post their profiles and find a “sugar-daddy” who will finance their tuition in exchange for companionship and sex.

Ø “States that attempt to close that loophole fail, says Scott Cunningham, an Economics professor at Baylor University in Texas who has studied prostitution markets. Proposed legislation against the practice might, he says, inadvertently prohibit marriage- which could, after all, be defined as intercourse for financial support[3].

Article 2. No marriage shall be valid, unless these essential requisites are present:

1)Legal capacity of the contracting parties who must be a male and a female; and
2)Consent freely given in the presence of the solemnizing officer.

Article 3. The formal requisites of marriage are:

1)Authority of the solemnizing officer;
2)A valid marriage license except in the cases provided for in Chapter 2 of this Title; and
3)A marriage ceremony which takes place with the appearance of the contracting parties before the solemnizing officer and their personal declaration that they take each other as husband and wife in the presence of not less than two witnesses of legal age.

Article 4. The absence of any of the essential or formal requisites shall render the marriage void ab initio, except as stated in Article 35 (2).

            A defect in any of the essential or formal requisites shall render the marriage voidable as provided in Article 45.

            An irregularity in the formal requisites shall not affect the validity of the marriage but the party or parties responsible for the irregularity shall be civilly, criminally and administratively liable.

Article 5. Any male or female of the age of eighteen years or upwards not under any of the impediments mentioned in Articles 37 and 38, may contract marriage.

Article 6. No prescribed form or religious rite for the solemnization of the marriage is required. It shall be necessary, however, for the contracting parties to personally appear before the solemnizing officer and declare in the presence of not less than two witnesses of legal age that they take each other as husband and wife. This declaration shall be contained in the marriage certificate which shall be signed by the contracting parties and their witnesses and attested by the solemnizing officer.

            In case of a marriage in articulo mortis, when the party at the point of death is unable to sign the marriage certificate, it shall be sufficient for one of the witnesses to the marriage to write the name of said party, which facts shall be attested by the solemnizing officer.

Article 7. Marriage may be solemnized by:
1) Any incumbent member of the judiciary within the court’s jurisdiction;

x x x”

-        Marriage must be between male and female. This is a statutory requirement, not Constitutional

-        Effect of Sex Change

-        Silverio v. Republic[4] doctrine v. Republic v. Cagandahan[5] ruling
Congenital Adrenal Hyperplasia (CAH)

·       Navarro v. Domagtoy, A.M. No. MTJ 06-1088, July 19, 1996
·       “Where judge solemnizes a marriage outside his court’s jurisdiction, there is a resultant irregularity in the formal requisite laid down in Article 3 which while it may not affect the validity of the marriage may subject the officiating official to administrative liability.”
·       “Just an obiter-dictum. Non observance of this rule is not a mere irregularity because it generally makes the marriage void”.


Article 22. The marriage certificate, x x x”

  
-Proof of Marriage. Circado-Belison v. Circado, Jr. (2015)[6]
-Contrato Matrimonial issued by Church of Filipino Independiente, Sec. 20, Rule 132- Is a private document
-Earlier baptismal certificate v. Later Certificate of Marriage from Local Civil Registrar


Article 26. All marriages solemnized outside the Philippines, in accordance with the laws in force in the country where they were solemnized, and valid there as such, shall also be valid in this country, except those prohibited under Articles 35 (1), (4), (5) and (6), 36, 37 and 38.

            Where a marriage between a Filipino citizen and a foreigner is validly celebrated and a divorce is thereafter validly obtained abroad by the alien spouse capacitating him or her to remarry, the Filipino spouse shall likewise have capacity to remarry under Philippine law.

Gen. Rule- Lex Loci Celebrationes 
 Exception: nationality principle & Article 17 on Prohibitive Laws, and Articles 35 (1), (4), (5) and (6), 36, 37 and 38.

- minor, bigamous marriage, mistake in identity, subsequent void marriage, psychological incapacity, bigamous, incestuous marriages and contrary to public policy.

-        Mixed-Marriage
-        RECKONING POINT. “For purposes of Article 26 therefore, the DETERMINATIVE POINT when the foreigner is at THE TIME OF THE DIVORCE and not at the time of marriage”[7].
-        Dual Citizen. “In the event that the former Filipino spouse who has been naturalized as a foreign citizen decides to return to the Philippines and reacquire Philippine citizenship, the divorce decree will still be recognized here because at the time of the issuance of the decree of divorce and at the time of the issuance of the decree of divorce, he or she was not a citizen of the Philippines”[8].

-        May the foreigner spouse avail of the benefits of the 2nd paragraph of Article 26?

-        Hypotheticals:

1)     X, an American; and Y, a Filipino, got married. If X obtains a divorce decree abroad which capacities him to remarry. May X file a petition to dissolve his marriage in the Philippine courts?

2)    A and B, both Filipinos, are spouses. They emigrated to the US, embraced US citizenship and there obtained a Divorce decree.  A, the husband, returns to the Philippines and meets and falls in love with a Filipino. When he wanted to marry the Filipina, he presented the divorce decree to the local civil registrar who refused to accept it and required him to present a court order from a Philippine court which dissolves his marriage with B before a marriage license will be issued. Is the Local Civil Registrar correct?

3)    In question No. 1, if it is Y, the Filipino spouse, who will file the petition, what legal provision should she invoke? In which court should she file her petition?

4)   In question No. 2, where will A file his petition? And what procedure will be applied by the court once such petition is filed?  

-         Read: Corpus v. Sto. Tomas[9], Bayot v. Court of Appeals[10], Roehr v. Rodriguez[11].




[1] Prof. Sta. Maria, pp. 99-100 PERSONS AND FAMILY RELATIONS 2015 citing Bove v. Pinciotti, 46 Pa D & C [C.P. 1942])
[2] G.R. No. 198780, October 16, 2013
[3] “Paying for College, A teaspoon of sugar”, See pp. 38-39, The Economist June 20th 2015
[4] G.R. No. 174689, October 19, 2007
[5] G.R. No. 166676, September 12, 2008
[6] G.R. No. 185374, March 11, 2015
[7] P. 181, Prof. Sta Maria, Id. , citing Republic v. Orbecido III, G.R. No. 154380, October 5, 2005
[8] Prof. Sta. Maria, Ibid.
[9] G.R. No. 186571, August 11, 2010
[10] G.R. No. 155635/ 163979, November 7, 2008
[11] G.R. No. 142820, June 20, 2003

No comments:

Post a Comment