**Facts:**
1. **Background:** On July 1978, Karl Heinz Wiegel and Lilia Oliva Wiegel were married at the Holy Catholic Apostolic Christian Church Branch in Makati, Metro Manila.
2. **Complaint Filed:** Karl Heinz Wiegel filed an action (Family Case No. 483) before the Juvenile and Domestic Relations Court of Caloocan City seeking the declaration of nullity of his marriage to Lilia on the ground that Lilia was previously and still legally married to Eduardo A. Maxion, with the ceremony having taken place on June 25, 1972, at Our Lady of Lourdes Church in Quezon City.
3. **Lilia’s Admission:** Lilia admitted the existence of the prior marriage but claimed it was null and void because she and Eduardo A. Maxion had been forced into the union.
4. **Pre-Trial Issue:** During pre-trial, the parties agreed to focus on whether the force exerted on both parties made the first marriage void or merely voidable.
5. **Motion to Present Evidence:** Contesting the validity of the pre-trial order, Lilia sought to present evidence that the first marriage was null due to force and because Eduardo was allegedly already married to someone else at the time of their marriage.
6. **Respondent Judge’s Orders:** The respondent judge refused Lilia’s request, ruling that the existence of force had already been established as agreed upon in the pre-trial.
7. **Order Contents:** The judge issued orders (dated March 17, 1980, and April 14, 1980) compelling the parties to submit the case for resolution based on “agreed facts” and denying Lilia’s motion to present evidence.
8. **Certiorari Petition:** Lilia filed a petition for certiorari challenging these orders.
**Issues:**
1. **Validity of the First Marriage:** Whether the first marriage of Lilia, entered into under duress, was void or merely voidable.
2. **Evidence of Prior Marriage Annulment:** Whether Lilia should be allowed to present evidence that her first husband was already in a valid marriage at the time they married each other.
**Court’s Decision:**
1. **Validity of First Marriage:**
– The Court determined that even if the first marriage was entered into under duress, it would only be voidable under Article 85 of the Civil Code, requiring annulment to be deemed void. Since no annulment had been decreed, Lilia’s first marriage was thus considered valid at the time she married Karl Heinz Wiegel.
– Consequently, Lilia’s marriage to Karl Heinz Wiegel was declared void for bigamy, based on Article 80 of the Civil Code.
2. **Evidence of Prior Marriage:**
– The Court noted that presenting evidence of Eduardo A. Maxion’s alleged prior existing marriage would not impact Lilia’s status at the time of her marriage to Karl Heinz Wiegel.
– The Court cited that, even if Eduardo’s prior marriage rendered his marriage with Lilia void, a judicial declaration to that effect was still required. Hence, for all legal purposes, Lilia was still considered a married woman at the time she married Karl Heinz Wiegel, rendering the latter marriage void.
The petition for certiorari was dismissed for lack of merit, and the orders of the respondent judge were affirmed. Costs were assessed against the petitioner.
**Doctrine:**
1. **Voidable Marriages:** A marriage entered into under duress or force is not void ab initio but merely voidable and requires judicial annulment (Art. 85, Civil Code).
2. **Bigamy:** If a person contracts a second marriage while a prior valid marriage still exists, the second marriage is void (Art. 80, Civil Code).
3. **Judicial Declaration of Nullity:** A marriage alleged to be void due to an existing prior marriage requires a judicial declaration to that effect for it to be legally recognized as such.
**Class Notes:**
1. **Key Elements of Voidable Marriages:**
– Consent vitiated by force, intimidation, or undue influence (Art. 85, Civil Code).
– Requires a judicial annulment to declare it null.
2. **Bigamy:**
– Contracting a marriage while a previous one is still subsisting and valid (Art. 80, Civil Code).
– The second marriage is automatically void without needing separate annulment if the prior marriage is proven valid.
3. **Judicial Declaration Requirement:**
– Even void marriages (like bigamous ones) need a judicial declaration for legality and enforcement in certain contexts.
**Historical Background:**
The case is contextualized in Philippine family law under the Civil Code provisions regarding marriage and nullity. During this period, annulments and judicial declarations of nullity were critical procedural steps in distinguishing the validity of marriages. The judiciary was meticulous in ensuring regulatory compliance to prevent forms of marital fraud and uphold societal norms on the sanctity of marriage.
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