The Supreme Court’s decision in Enrico v. Heirs of Sps. Medinaceli clarifies that only a husband or wife can directly file a petition for the declaration of nullity of their marriage under the Family Code. While heirs cannot file such a petition directly, they are not without recourse; they can still challenge the validity of a marriage in a proceeding for the settlement of the deceased spouse’s estate. This distinction ensures that while the right to question a marriage’s validity is primarily personal, the inheritance rights of heirs are protected through estate proceedings, balancing spousal exclusivity with familial interests in property.

Family Code Marriage: Can Heirs Contest After a Spouse’s Death?

The case revolves around Lolita D. Enrico’s marriage to Eulogio B. Medinaceli, which was challenged by Eulogio’s children from a prior marriage after his death. The children sought to declare the marriage null and void, arguing that it was entered into without a valid marriage license, as their father had been married to their mother until her recent death. This raised a crucial legal question: Can the heirs of a deceased spouse file a petition to declare the nullity of that spouse’s marriage, particularly when the marriage was solemnized under the Family Code? The Regional Trial Court (RTC) initially dismissed the case but later reinstated it, leading to this appeal.

The Supreme Court addressed the issue of whether the heirs of a deceased spouse have the legal standing to file a petition for the declaration of nullity of marriage. The Court referenced A.M. No. 02-11-10-SC, also known as the Rule on Declaration of Absolute Nullity of Void Marriages and Annulment of Voidable Marriages, which explicitly states that only the husband or wife can file such a petition. This rule, however, applies specifically to marriages entered into during the effectivity of the Family Code. In this context, the Court differentiated this case from Niñal v. Bayadog, where the marriage in question occurred before the Family Code’s enactment.

Building on this principle, the Court emphasized the importance of the Family Code. Because Eulogio and Lolita’s marriage occurred in 2004, the Family Code provisions were directly applicable, thereby making A.M. No. 02-11-10-SC controlling. The pertinent provision states:

Section 2. Petition for declaration of absolute nullity of void marriages. –
(a) Who may file. – A petition for declaration of absolute nullity of void marriage may be filed solely by the husband or the wife.

This explicit wording makes it unequivocally clear that only the spouses themselves, not their heirs, can directly initiate a nullity case. The Supreme Court reinforced this stance by citing the rationale behind the rules, explaining that heirs possess only inchoate rights before the death of their predecessor. These rights do not allow them to directly challenge the validity of a marriage, but rather to do so during estate settlement proceedings.

Nevertheless, the Court also clarified that the heirs are not entirely without legal recourse. While they cannot file a separate petition for nullity, they can challenge the marriage’s validity when settling the deceased spouse’s estate. This ensures that the heirs’ successional rights are protected without disrupting the personal nature of actions for declaring a marriage void. The Court, therefore, had to balance the right of a spouse to determine the course of their marital status during their lifetime against the inheritance claims of the heirs upon the death of a spouse.

Furthermore, the decision underscores the principle of absolute sententia expositore non indiget—when the language of the law is clear, no explanation is required. Since A.M. No. 02-11-10-SC distinctly limits the filing of nullity petitions to the spouses themselves, the RTC’s decision to reinstate the heirs’ complaint was deemed an act of grave abuse of discretion. The Supreme Court’s interpretation aligns with preserving the intent and framework of the Family Code while recognizing the complexities that arise in inheritance disputes.

FAQs

What was the key issue in this case?	The central issue was whether the heirs of a deceased spouse could file a petition to declare the nullity of that spouse’s marriage under the Family Code, specifically in light of A.M. No. 02-11-10-SC.
Who can file a petition for declaration of nullity of marriage under the Family Code?	Under A.M. No. 02-11-10-SC, only the husband or the wife can file a petition for declaration of absolute nullity of a void marriage.
What is A.M. No. 02-11-10-SC?	A.M. No. 02-11-10-SC is the Rule on Declaration of Absolute Nullity of Void Marriages and Annulment of Voidable Marriages, which governs petitions for nullity and annulment under the Family Code.
What recourse do heirs have if they cannot directly file a nullity petition?	Heirs can challenge the validity of the marriage in a proceeding for the settlement of the estate of the deceased spouse filed in the regular courts.
How does this case differ from Niñal v. Bayadog?	Niñal v. Bayadog involved a marriage solemnized before the effectivity of the Family Code, whereas this case concerns a marriage under the Family Code, making A.M. No. 02-11-10-SC applicable.
What does absolute sententia expositore non indiget mean?	It means that when the language of the law is clear, no explanation of it is required. This principle was invoked because A.M. No. 02-11-10-SC plainly states who may file a nullity petition.
When did the Family Code take effect?	The Family Code took effect on August 3, 1988, one year after its publication in a newspaper of general circulation.
Are the heirs’ rights completely disregarded by this ruling?	No, the heirs retain the right to question the validity of the marriage during estate settlement proceedings, ensuring their successional rights are protected.

In conclusion, while the Supreme Court affirmed the exclusivity of spouses in filing for the declaration of nullity of marriage under the Family Code, it carefully preserved the rights of heirs to contest the validity of marriages in estate proceedings. This decision underscores the importance of adhering to procedural rules while safeguarding substantive rights within the framework of family law.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: LOLITA D. ENRICO, PETITIONER, VS. HEIRS OF SPS. EULOGIO B. MEDINACELI AND TRINIDAD CATLI-MEDINACELI, REPRESENTED BY VILMA M. ARTICULO, RESPONDENTS., G.R. No. 173614, September 28, 2007