Case Digest: Castillo vs. De Leon Castillo

2025-09-28

Renato A. Castillo vs. Lea P. De Leon Castillo
G.R. No. 189607 • April 18, 2016
Sereno, C.J.

Facts

In 1972, Lea first married Benjamin Bautista. In 1979, she entered her second marriage with Renato.
In 2001, Renato filed a petition before the RTC to declare his marriage with Lea void ab initio due to bigamy and psychological incapacity.
Lea opposed, contending that her first marriage was null and void due to absence of license and a defect in solemnization. In 2002, Lea petitioned before the RTC to declare her first marriage void. It was granted by RTC in 2003.
The RTC ruled in 2007 declaring Renato’s marriage with Lea null and void ab initio based on a bigamous marriage.
In 2009, the Court of Appeals reversed the decision of the RTC, citing that both marriages were solemnized before the promulgation of the Family Code, and the Civil Code, which does not require any judicial action to declare a marriage null and void ab initio, is applicable.

Whether the CA ruling is correct in upholding Lea and Renato’s marriage; and
Whether the Family Code can be retroactively applied to marriages celebrated before its promulgation.

Renato’s petition is DENIED. The 2009 CA decision is AFFIRMED.

The Civil Code applies to both marriages. – The Court upheld that Lea’s marriage with both Bautista and Renato and all of its incidents are determined in accordance with the Civil Code, the law in effect at the time of both celebrations of marriages. The Family Code cannot be retroactively applied to the case as it would prejudice the vested rights of the children, as per Jison (1998).
The Civil Code requires no judicial decree in declaring a marriage void ab initio. – It is clearly defined in cases of nullity of marriage under the Civil Code: Mendoza (1954), Aragon (1957), and Odayat (1977).