CONFLICT OF LAW

DIGEST CASES re: MARRIAGE AND DIVORCE

ANGELICA BELLADONNA C. LEONOR

LLB- III, BICOL COLLEGE

US VS. JARVISON

FACTS: This appeal centers around Esther Jarvison's refusal to testify against Ben
Jarvison in a criminal case in which Jarvison is accused of sexually abusing their
granddaughter, Jane Doe. After the government indicted Jarvison for aggravated sexual
abuse of a minor child in Indian Country, it attempted to compel Esther to testify against
Jarvison.

The government argued that the marriage was not valid because:  (1) Esther had not
testified to every element of a “traditional ceremony” under the Navajo Code;  (2) the
Jarvisons had not recorded the traditional marriage with the Navajo tribal government;
 and (3) an intervening relationship with Esther's daughter had extinguished any
marriage. In this case, Esther testified to having married Jarvison in a traditional
Navajo ceremony on June 25, 1953 at Coyote Canyon within the Navajo Reservation.
She identified the particular Navajo medicine man who performed the ceremony.
Although the government makes much of the fact that Esther did not testify to the exact
requirements outlined in the Navajo Code provision, the statute itself requires only that
the couple “engage in a traditional Navajo wedding ceremony which shall have
substantially the following features ․”

ISSUE: Whether Esther and Ben’ Jarvinson’s marriage valid under the Navajo Code?

HELD: The Navajo Domestic Code takes care to maintain the validity of prior marriages
that would not necessarily meet current code requirements for marriage. In addition to
longstanding Navajo common law and current Navajo Code recognizing unlicensed or
unvalidated traditional marriages performed at times when licenses were ostensibly
required, current Navajo law does not necessarily require a license. Thus, the
government's contention that the Jarvisons' marriage is invalid because they did not

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have their marriage validated or licensed fails under Navajo law. Despite the district
court's failure to make specific findings of fact underpinning its determination of a valid
marriage, sufficient evidence is in the record validating the Jarvisons' marriage for the
purposes of the spousal testimonial privilege.

COOK VS. COOK

FACTS: In the case at bar, the petitioner and respondent were first cousins which were
married in Virginia. Such marriage is deemed valid in Virginia. Subsequently, they
moved to Arizona where marriages between cousins are prohibited except those
marriages held valid by the laws where they are contracted. Afterward, an amendment
to Arizona marriage laws made those previously held valid marriages as now void and
prohibited.

ISSUES: Whether or not the marriage is valid under Arizona law.

HELD: YES. According to Arizona law, no statute is retroactive unless expressly

declared therein, and there was no express declaration as such. Also, since appellee
has a vested right in the validity of her marriage that includes a “vested property
interest”, such is harmonized to the already prospective construction of such
amendatory statute.

OBERGEFELL VS. HODGES

FACTS: Groups of same-sex couples sued their relevant state agencies in Ohio,
Michigan, Kentucky, and Tennessee to challenge the constitutionality of those states'
bans on same-sex marriage or refusal to recognize legal same-sex marriages that
occurred in jurisdictions that provided for such marriages. The plaintiffs in each case
argued that the states' statutes violated the Equal Protection Clause and Due Process
Clause of the Fourteenth Amendment, and one group of plaintiffs also brought claims
under the Civil Rights Act. In all the cases, the trial court found in favor of the plaintiffs.
The U.S. Court of Appeals for the Sixth Circuit reversed and held that the states' bans
on same-sex marriage and refusal to recognize marriages performed in other states did

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not violate the couples' Fourteenth Amendment rights to equal protection and due
process.

ISSUES: (1) Does the Fourteenth Amendment require a state to license a marriage
between two people of the same sex?

(2) Does the Fourteenth Amendment require a state to recognize a marriage between
two people of the same sex that was legally licensed and performed in another state?

Ruling:

The Court upheld the rights of same-sex couples to marry. It opined that the Fourteenth
Amendment requires a State to license a marriage between two people of the same sex
based on the following principles and premises:

(1) The fundamental liberties protected by the Fourteenth Amendment’s Due Process
Clause extend to certain personal choices central to individual dignity and autonomy,
including intimate choices defining personal identity and beliefs.

(2) Four principles and traditions demonstrate that the reasons marriage is fundamental
under the Constitution apply with equal force to same-sex couples.

(a) The first premise of this Court’s relevant precedents is that the right to personal
choice regarding marriage is inherent in the concept of individual autonomy.

(b) A second principle in this Court’s jurisprudence is that the right to marry is
fundamental because it supports a two-person union unlike any other in its importance
to the committed individuals. The intimate association protected by this right was central
to Griswold v. Connecticut, which held the Constitution protects the right of married
couples to use contraception.

(c) A third basis for protecting the right to marry is that it safeguards children and
families and thus draws meaning from related rights of childrearing, procreation, and
education.

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(d) Finally, this Court’s cases and the Nation’s traditions make clear that marriage is a
keystone of the Nation’s social order. States have contributed to the fundamental
character of marriage by placing it at the center of many facets of the legal and social
order. There is no difference between same- and opposite-sex couples with respect to
this principle, yet same-sex couples are denied the constellation of benefits that the
States have linked to marriage and are consigned to an instability many opposite-sex
couples would find intolerable. It is demeaning to lock same-sex couples out of a central
institution of the Nation’s society, for they too may aspire to the transcendent purposes
of marriage.

The limitation of marriage to opposite-sex couples may long have seemed natural and
just, but its inconsistency with the central meaning of the fundamental right to marry is
now manifested.

(3) The right of same-sex couples to marry is also derived from the Fourteenth
Amendment’s guarantee of equal protection. The Due Process Clause and the Equal
Protection Clause are connected in a profound way. Rights implicit in liberty and rights
secured by equal protection may rest on different precepts and are not always
coextensive, yet each may be instructive as to the meaning and reach of the other.

(4) The right to marry is a fundamental right inherent in the liberty of the person, and
under the Due Process and Equal Protection Clauses of the Fourteenth Amendment
couples of the same-sex may not be deprived of that right and that liberty. Same-sex
couples may exercise the fundamental right to marry.

(5) While the Constitution contemplates that democracy is the appropriate process for
change, individuals who are harmed need not await legislative action before asserting a
fundamental right.

TENCHAVEZ VS. ESCANO

FACTS: Vicenta Escano, 27 years old, who belong to a prominent Filipino family of
Spanish ancestry got married on Feburary 24, 1948 with Pastor Tenchavez, 32 years
old engineer, and ex-army officer before Catholic chaplain Lt. Moises Lavares. The
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marriage was a culmination of the love affair of the couple and was duly registered in
the local civil registry. A certain Pacita Noel came to be their match-maker and go-
between who had an amorous relationship with Tenchavez as written by a San Carlos
college student where she and Vicenta are studying. Vicenta and Pastor are supposed
to renew their vows/ marriage in a church as suggested by Vicenta’s parents. However
after translating the said letter to Vicenta’s dad , he disagreed for a new marriage.
Vicenta continued leaving with her parents in Cebu while Pastor went back to work in
Manila.

Vicenta applied for a passport indicating that she was single and when it was approved
she left for the United States and filed a complaint for divorce against Pastor which was
later on approved and issued by the Second Judicial Court of the State of Nevada. She
then sought for the annulment of her marriage to the Archbishop of Cebu. Vicenta
married Russell Leo Moran, an American, in Nevada and has begotten children. She
acquired citizenship on August 8, 1958. Petitioner filed a complaint against Vicenta and
her parents whom he alleged to have dissuaded Vicenta from joining her husband.

ISSUE: Whether the divorce sought by Vicenta Escano is valid and binding upon courts
of the Philippines.

HELD: The Civil Code of the Philippines does not admit divorce. Philippine courts
cannot give recognition on foreign decrees of absolute divorce between Filipino citizens
because it would be a violation of the Civil Code. Such grant would arise to
discrimination in favor of rich citizens who can afford divorce in foreign countries. The
adulterous relationship of Escano with her American husband is enough grounds for the
legal separation prayed by Tenchavez. In the eyes of Philippine laws, Tenchavez and
Escano are still married. A foreign divorce between Filipinos sought and decreed is not
entitled to recognition neither is the marriage of the divorcee entitled to validity in the
Philippines. Thus, the desertion and securing of an invalid divorce decree by one
spouse entitled the other for damages.

VAN DORN VS. ROMILLO

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FACTS: Alice Reyes Van Dorn, a Filipino Citizen and private respondent, Richard
Upton, a US citizen, was married in Hong Kong in 1979. They established their
residence in the Philippines and had 2 children. They were divorced in Nevada, USA in
1982 and petitioner remarried, this time with Theodore Van Dorn. A suit against
petitioner was filed on June 8, 1983, stating that petitioner’s business in Ermita Manila,
the Galleon Shop, is a conjugal property with Upton and prayed therein that Alice be
ordered to render an accounting of the business and he be declared as the
administrator of the said property.

ISSUE: Whether or not the foreign divorce between the petitioner and private
respondent in Nevada is binding in the Philippines where petitioner is a Filipino citizen.

HELD: Private respondent is no longer the husband of the petitioner. He would have no
standing to sue petitioner to exercise control over conjugal assets. He is estopped by
his own representation before the court from asserting his right over the alleged
conjugal property. Furthermore, aliens may obtain divorces abroad, which may be
recognized in the Philippines, provided they are valid according to their national law.
Petitioner is not bound to her marital obligations to respondent by virtue of her
nationality laws. She should not be discriminated against her own country if the end of
justice is to be served.

SAN LUIS V. SAN LUIS

FACTS: During his lifetime, Felicisimo San Luis contracted three marriages. His first
marriage was with Virginia Sulit on March 17, 1942 out of which were born six children.
On August 11, 1963, Virginia predeceased Felicisimo.

Five years later, on May 1, 1968, Felicisimo married Merry Lee Corwin, with whom he
had a son, Tobias. However, on October 15, 1971, Merry Lee, an American citizen, filed
a Complaint for Divorce before the Family Court of the First Circuit, State of Hawaii,
which issued a Decree Granting Absolute Divorce and Awarding Child Custody on
December 14, 1973. On June 20, 1974, Felicisimo married Felicidad San Luis, then
surnamed Sagalongos. He had no children with Felicidad but lived with her for 18 years

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from the time of their marriage up to his death on December 18, 1992. Upon death of
his dad, Rodolfo sought the dissolution of their Felicisimo’s conjugal partnership assets
and the settlement of Felicisimo’s estate. On December 17, 1993, Felicidad filed a
petition for letters of administration before the Regional Trial Court of Makati City.
Rodolfo claimed that Felicidad has no legal personality to file the petition because she
was only a mistress of Felicisimo since the latter, at the time of his death, was still
legally married to Merry Lee. Felicidad presented the decree of absolute divorce issued
by the Family Court of the First Circuit, State of Hawaii to prove that the marriage of
Felicisimo to Merry Lee had already been dissolved. Thus, she claimed that Felicisimo
had the legal capacity to marry her by virtue of paragraph 2 Article 26 of the Family
Code.

Rodolfo asserted that paragraph 2, Article 26 of the Family Code cannot be given
retroactive effect to validate Felicidad’s bigamous marriage with Felicisimo because this
would impair vested rights in derogation of Article 256.

ISSUE: Whether or not Felicidad may file for letters of administration over Felicisimo’s
estate.

HELD: The divorce decree allegedly obtained by Merry Lee which absolutely allowed
Felicisimo to remarry, would have vested Felicidad with the legal personality to file the
present petition as Felicisimo’s surviving spouse. However, the records show that there
is insufficient evidence to prove the validity of the divorce obtained by Merry Lee as well
as the marriage of Felicidad and Felicisimo under the laws of the U.S.A. In Garcia v.
Recio, the Court laid down the specific guidelines for pleading and proving foreign law
and divorce judgments. It held that presentation solely of the divorce decree is
insufficient and that proof of its authenticity and due execution must be presented.
Under Sections 24 and 25 of Rule 132, a writing or document may be proven as a
public or official record of a foreign country by either (1) an official publication or (2) a
copy thereof attested by the officer having legal custody of the document. If the record
is not kept in the Philippines, such copy must be (a) accompanied by a certificate issued
by the proper diplomatic or consular officer in the Philippine foreign service stationed in

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the foreign country in which the record is kept and (b) authenticated by the seal of his
office.

With regard to Felicidad’s marriage to Felicisimo allegedly solemnized in California,

U.S.A., she submitted photocopies of the Marriage Certificate and the annotated text of
the Family Law Act of California which purportedly show that their marriage was done in
accordance with the said law. As stated in Garcia, however, the Court cannot take
judicial notice of foreign laws as they must be alleged and proved.

The case should be remanded to the trial court for further reception of evidence on the
divorce decree obtained by Merry Lee and the marriage of respondent and Felicisimo.

PILAPIL vs. IBAY SOMERA

FACTS: On September 7, 1979, Imelda Manalaysay Pilapil, a Filipina and Erich Geiling
were married at Friedenweiler in the Federal Republic of Germany. After about three
and a half years of marriage, Geiling initiated a divorce proceeding against Pilapil in
Germany in January 1983.

Pilapil, petitioner, on the other hand, filed an action for legal separation, support and
separation of property before RTC of Manila on January 23, 1983 where it is still
pending as a civil case. On January 15, 1986, the local Court of Germany promulgated
a divorce decree on the ground of failure of marriage of the spouses. The custody of the
child was granted to petitioner.

On June 27, 1986, private respondent filed two complaints for adultery alleging that,
while still married to respondent, petitioner “had an affair with a certain William Chua as
early as 1982 and with yet another man named Jesus Chua sometime in 1983. The
respondent city fiscal approved a resolution directing the filing of two complaints for
adultery against petitioner. Thereafter, petitioner filed a motion in both criminal cases to
defer her arraignment and to suspend further proceedings thereon. Respondent judge
merely reset the date of the arraignment but before such scheduled date, petitioner
moved for the suspension of proceedings. On September 8, 1987, respondent judge
denied the motion to quash and also directed the arraignment of both accused.
Petitioner refused to be arraigned and thus charged with direct contempt and fined.”
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ISSUE: Whether or not the case for adultery should prosper.

RULING: The petition entered dismissing the complaint in criminal case was upheld for
lack of jurisdiction. The temporary restraining order issued in this case was made
permanent. The law provides that in prosecutions for adultery and concubinage the
person who can legally file the complaint should be the offended spouse. The fact that
private respondent obtained a valid divorce in his country, is admitted. Private
respondent, being no longer married to petitioner has no legal standing to commence
the adultery case under the posture that he was the offended spouse at the time he filed
suit.

ROEHR V. RODRIGUEZ

FACTS: Petitioner Wolfgang O. Roehr, a German citizen, married private respondent

Carmen Rodriguez, a Filipina, on December 11, 1980 in Germany. Their marriage was
subsequently ratified on February 14, 1981 in Tayasan, Negros Oriental. Out of their
union were born Carolynne and Alexandra Kristine.
Carmen filed a petition for declaration of nullity of marriage before the Makati Regional
Trial Court (RTC). Wolfgang filed a motion to dismiss, but it was denied.

Meanwhile, Wolfgang obtained a decree of divorce from the Court of First Instance of
Hamburg-Blankenese. Said decree also provides that the parental custody of the
children should be vested to Wolfgang.

Wolfgang filed another motion to dismiss for lack of jurisdiction as a divorce decree had
already been promulgated, and said motion was granted by Public Respondent Judge
Salonga.
Carmen filed a Motion for Partial Reconsideration, with a prayer that the case proceed
for the purpose of determining the issues of custody of children and the distribution of
the properties between her and Wolfgang. Judge Salonga partially set aside her
previous order for the purpose of tackling the issues of support and custody of their
children.

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ISSUE: W/N there is nothing left to be tackled by the Court since there are no conjugal
properties alleged in the annulment and the divorce decree provides for the finality of
the custody of children.

RULING: No. As a general rule, divorce decrees obtained by foreigners in other

countries are recognizable in our jurisdiction, but the legal effects thereof, e.g. on
custody, care and support of the children, must be determined by our courts. The Court
held that before our courts can give the effect of res judicata to a foreign judgment, such
as the award of custody to petitioner by the German court, it must be shown that the
parties opposed to the judgment had been given ample opportunity to do so on grounds
allowed under Rule 39, Section 50 of the Rules of Court.

Pursuant to Article 26 of the Family Code, 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 have
capacity to remarry under Philippine law. (As amended by Executive Order 227)
Moreover, Section 50 of the Rules of Court states that the effect of a judgment of a
tribunal of a foreign country, having jurisdiction to pronounce the judgment is as follows:

(a) In case of a judgment upon a specific thing, the judgment is conclusive upon the title
to the thing;

(b) In case of a judgment against a person, the judgment is presumptive evidence of a

right as between the parties and their successors in interest by a subsequent title; but
the judgment may be repelled by evidence of a want of jurisdiction, want of notice to the
party, collusion, fraud, or clear mistake of law or fact.

Since the proceedings in the German court were summary, the wife was not given
opportunity to challenge said judgment. Therefore, the divorce decree did not provide
for the finality of the custody of children.

REPUBLIC VS. ORBECIDO

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FACTS: Cipriano Orbecido III was married with Lady Myros Villanueva on May 24, 1981
at the United Church of Christ in the Philippines in Ozamis City. They had a son and a
daughter named Kristoffer and Kimberly, respectively. In 1986, the wife left for US
bringing along their son Kristoffer. A few years later, Orbecido discovered that his wife
had been naturalized as an American citizen and learned from his son that his wife
sometime in 2000 had obtained a divorce decree and married a certain Stanley. He
thereafter filed with the trial court a petition for authority to remarry invoking Paragraph 2
of Article 26 of the Family Code.

ISSUE: Whether or not Orbecido can remarry under Article 26 of the Family Code.

HELD: The court ruled that taking into consideration the legislative intent and applying
the rule of reason, Article 26 Par.2 should be interpreted to include cases involving
parties who, at the time of the celebration of the marriage were Filipino citizens, but later
on, one of them becomes naturalized as a foreign citizen and obtains a divorce decree.
The Filipino spouse should likewise be allowed to remarry as if the other party were a
foreigner at the time of the solemnization of the marriage. Hence, the court’s unanimous
decision in holding Article 26 Par 2 be interpreted as allowing a Filipino citizen who has
been divorced by a spouse who had acquired a citizenship and remarried, also to
remarry under Philippine law.

CORPUZ VS. STO. TOMAS

FACTS: Gerbert Corpuz, a former Filipino citizen but now a naturalized Canadian,
married Daisylyn Sto. Tomas, a Filipina. He soon left to Canada after their wedding due
to work commitments. He returned to Philippines on April 2005 only to find out Daisylyn
has an affair with another man. Gerbert returned to Canada to file a divorce that took
effect on January 2006.

Two years later, he found another Filipina and wanted to marry her in the Philippines.
He went to Pasig City Registrar's Office to register his Canadian divorce decree but was
denied considering that his marriage with Daisylyn still subsists under Philippine law,
that the foregin divorce must be recognized judicially by the Philippine court.

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Gerbert subsequently filed at the Regional Trial Court a judicial recognition of foreign
divorce but was subsequently denied since he is not the proper party and according to
Article 26 of the Civil Code, only a Filipino spouse can avail the remedy.

ISSUE: Whether or not Article 26 can also be applied to Corpuz' petition of recognition
of the foreign divorce decree

HELD: The Court held that alien spouses cannot claim the right as it is only in favor of
Filipino spouses. The legislative intent of Article 26 is for the benefit of the clarification of
the marital status of the Filipino spouse. However, aliens are not strip to petition to the
RTC for his foreign divorce decree as it is a conclusive presumption of evidence of the
authenticity of foreign divorce decree with confirmity to the alien's national law. The
Pasig City Registrar's Office acted out of line when it registered the foreign divorce
decree without judicial order recognition. Therefore, the registration is still deemed to be
void.

MINORU FUJIKI v. MARIA PAZ GALELA MARINAY

Facts: Minoru Fujiki (Fujiki), the herein petitioner, is a Japanese national who married
respondent Maria Paz Galela Marinay (Marinay) in the Philippines on 23 January 2004.
The marriage did not sit well with petitioner's parents. Thus, Fujiki could not bring his
wife to Japan where he resides. Eventually, they lost contact with each other. In 2008,
Marinay met another Japanese, Shinichi Maekara (Maekara). Without the first marriage
being dissolved, Marinay and Maekara were married on 15 May 2008 in Quezon City,
Philippines. Maekara brought Marinay to Japan. However, Marinay allegedly suffered
physical abuse from Maekara. She left Maekara and started to contact Fujiki and
Marinay met in Japan and they were able to reestablish their relationship. In 2010, Fujiki
helped Marinay obtain a judgment from a family court in Japan which declared the
marriage between Marinay and Maekara void on the ground of bigamy. On 14 January
2011, Fujiki filed a petition in the RTC entitled: "Judicial Recognition of Foreign
Judgment (or Decree of Absolute Nullity of Marriage)." Fujiki prayed that the Japanese
Family Court judgment be recognized; that the bigamous marriage between Marinay
and Maekara be declared void ab initio under Articles 35 and 41 of the Family Code of
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the Philippines; and for the RTC to direct the Local Civil Registrar of Quezon City to
annotate the Japanese Family Court judgment on the Certificate of Marriage between
Marinay and Maekara and to endorse such annotation to the Office of the Administrator
and Civil Registrar General in the National Statistics Office (NSO). The RTC
immediately issued an Order dismissing the petition.

The RTC cited the following provisions of the Rule on Declaration of Absolute Nullity of
Void Marriages and Annulment of Voidable Marriages (A.M. No. 02-11-10-SC) Fujiki
moved that the Order be reconsidered. The petitioner contended that the Japanese
judgment was consistent with Article 35(4) of the Family Code of the Philippines on
bigamy and was therefore entitled to recognition by Philippine courts.

Issues: Whether the Rule on Declaration of Absolute Nullity of Void Marriages and
Annulment of Voidable Marriages (A.M. No. 02-11-10-SC) is applicable.

Ruling: A foreign judgment relating to the status of a marriage affects the civil status,
condition and legal capacity of its parties. However, the effect of a foreign judgment is
not automatic. To extend the effect of a foreign judgment in the Philippines, Philippine
courts must... determine if the foreign judgment is consistent with domestic public policy
and other mandatory laws.[60] Article 15 of the Civil Code provides that "Laws relating
to family rights and duties, or to the status, condition and legal capacity of persons are...
binding upon citizens of the Philippines, even though living abroad." This is the rule of
lex nationalii in private international law. Thus, the Philippine State may require, for
effectivity in the Philippines, recognition by Philippine courts of a foreign judgment...
affecting its citizen, over whom it exercises personal jurisdiction relating to the status,
condition and legal capacity of such citizen.

A petition to recognize a foreign judgment declaring a marriage void does not require
relitigation under a Philippine court of the case as if it were a new petition for declaration
of nullity of marriage. Philippine courts cannot presume to know the foreign laws under
which the... foreign judgment was rendered. They cannot substitute their judgment on
the status, condition and legal capacity of the foreign citizen who is under the

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jurisdiction of another state. Thus, Philippine courts can only recognize the foreign
judgment as a fact according to... the rules of evidence.

There is therefore no reason to disallow Fujiki to simply prove as a fact the Japanese
Family Court judgment nullifying the marriage between Marinay and Maekara on the
ground of bigamy. While the Philippines has no divorce law, the Japanese Family Court
judgment is fully... consistent with Philippine public policy, as bigamous marriages are
declared void from the beginning under Article 35(4) of the Family Code. Bigamy is a
crime under Article 349 of the Revised Penal Code. Thus, Fujiki can prove the existence
of the Japanese Family Court judgment... in accordance with Rule 132, Sections 24 and
25, in relation to Rule 39, Section 48(b) of the Rules of Court.

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