The Supreme Court ruled that a marriage is valid even if entered into solely to acquire foreign citizenship, provided all legal requirements are met and consent is freely given. This means that a marriage intended for immigration purposes is not automatically void, protecting the institution of marriage from being easily invalidated based on ulterior motives. The decision emphasizes that the State cannot dictate the motives behind marriage, as long as the essential and formal requisites are present, upholding the marriage’s validity under Philippine law.

The $2,000 Vow: Can a Marriage for Citizenship Be Annulled?

In Republic of the Philippines v. Liberty D. Albios, the central issue before the Supreme Court was whether a marriage contracted for the primary purpose of acquiring American citizenship, in exchange for $2,000, could be declared void ab initio due to lack of consent. The Regional Trial Court (RTC) and the Court of Appeals (CA) had both declared the marriage between Liberty Albios, the respondent, and Daniel Lee Fringer, an American citizen, as void from the beginning, finding that the essential requisite of consent was lacking. The lower courts likened the situation to a marriage in jest, where the parties never intended to establish a conjugal and family life but merely sought personal gain through immigration benefits.

The Office of the Solicitor General (OSG), representing the Republic of the Philippines, appealed the CA decision, arguing that despite the ulterior motive, both parties freely gave their consent to the marriage, fully aware of its benefits and consequences. The OSG contended that the motive behind the marriage should be distinguished from consent itself, asserting that motive is inconsequential to the marriage’s validity. This appeal brought the issue to the Supreme Court, requiring a thorough examination of Philippine marriage laws and the concept of consent.

The Supreme Court began its analysis by examining the phenomenon of marriage fraud in immigration, noting that many countries, including the United States, have laws to prevent individuals from using marriage solely to gain immigration benefits. The U.S. case of Bark v. Immigration and Naturalization Service established that a marriage is a sham if the couple did not intend to establish a life together at the time of their marriage. However, the Court highlighted that the standard for immigration purposes does not determine the legal validity of a marriage.

The Court then addressed the issue of whether a marriage declared fraudulent for immigration purposes is also legally void. It discussed conflicting views in U.S. jurisprudence, citing United States v. Rubenstein, which held that a marriage entered into solely to deceive others, with no intention of truly being married, lacks consent and is not a marriage at all. In contrast, the Court also cited Mpiliris v. Hellenic Lines, which validated a marriage entered into solely for immigration purposes. The discussion set the stage for the Court’s own determination under Philippine law.

In analyzing the case under the Family Code of the Philippines, the Supreme Court emphasized that consent is an essential requisite of marriage. Article 2 of the Family Code states this explicitly, and Article 4 provides that the absence of any essential requisite renders a marriage void ab initio. The Court elaborated that for consent to be valid, it must be freely given and made in the presence of a solemnizing officer. Furthermore, it specified that a “freely given” consent requires that the contracting parties willingly and deliberately enter into the marriage.

The Court noted that consent must be real, meaning it is not vitiated by fraud, force, intimidation, or undue influence. It must also be conscious and intelligent, meaning the parties understand the nature and consequences of their act. Applying these principles to Albios’ marriage, the Court found that consent was indeed present. The justices reasoned that the parties willingly and deliberately contracted the marriage with the specific intention of acquiring American citizenship. The Court stated:

There was a clear intention to enter into a real and valid marriage so as to fully comply with the requirements of an application for citizenship. There was a full and complete understanding of the legal tie that would be created between them, since it was that precise legal tie which was necessary to accomplish their goal.

The Supreme Court distinguished Albios’ marriage from a marriage in jest, which is a pretended marriage entered into as a joke, with no real intention of being bound. The Court emphasized that in a marriage in jest, there is a complete absence of consent. However, in Albios’ case, the parties had a clear intention to be bound to create the legal bond necessary for the citizenship application. The Court asserted that:

Only a genuine consent to be married would allow them to further their objective, considering that only a valid marriage can properly support an application for citizenship. There was, thus, an apparent intention to enter into the actual marriage status and to create a legal tie, albeit for a limited purpose. Genuine consent was, therefore, clearly present.

The Supreme Court acknowledged that the avowed purpose of marriage under Article 1 of the Family Code is to establish a conjugal and family life. However, the Court clarified that the possibility that the parties might have no real intention to establish a life together is insufficient to nullify a marriage freely entered into. The Court stated that a marriage may only be declared void or voidable under the grounds provided by law. The Court then added that:

There is no law that declares a marriage void if it is entered into for purposes other than what the Constitution or law declares, such as the acquisition of foreign citizenship. Therefore, so long as all the essential and formal requisites prescribed by law are present, and it is not void or voidable under the grounds provided by law, it shall be declared valid.

The Court noted that motives for entering into a marriage are varied and complex, and the State cannot dictate the kind of life a couple chooses to lead. It said that any attempt to regulate their lifestyle would infringe on their right to privacy and raise serious constitutional questions. The Court explained that marriages entered into for other purposes, such as convenience, companionship, money, status, or title, are equally valid, provided they comply with all legal requisites.

The Court also addressed whether the marriage could be considered voidable on the ground of fraud under Article 45(3) of the Family Code. The Court noted that only the circumstances listed under Article 46 of the Family Code may constitute fraud, such as non-disclosure of a previous conviction involving moral turpitude or concealment of a sexually transmitted disease. Entering into a marriage for the sole purpose of evading immigration laws does not qualify under any of the listed circumstances.

Thus, the Supreme Court held that the marriage between Liberty Albios and Daniel Lee Fringer was valid, despite the ulterior motive of acquiring American citizenship. The Court emphasized the importance of protecting the institution of marriage from being easily invalidated based on the whims and caprices of the contracting parties.

FAQs

What was the main issue in this case?	The main issue was whether a marriage contracted for the purpose of acquiring foreign citizenship can be declared void due to lack of consent. The court determined that such a marriage is not automatically void if all legal requirements are met.
What is the Family Code’s stance on marriage requisites?	The Family Code requires that consent be freely given and made in the presence of a solemnizing officer. The absence of these essential requisites will render a marriage void ab initio.
How does the court define valid consent in marriage?	Valid consent must be real, not vitiated by fraud, force, or intimidation, and the parties must understand the nature and consequences of their act. Willing participation and understanding of the marital bond indicate valid consent.
What is a marriage in jest, and how does it differ from this case?	A marriage in jest is a pretended marriage entered into as a joke with no real intention of being bound, indicating a complete absence of consent. This differs from the Albios case, where the parties intended to create a legal bond for citizenship purposes.
Can ulterior motives invalidate a marriage under Philippine law?	No, ulterior motives such as acquiring citizenship do not automatically invalidate a marriage if the essential and formal requisites are present. The law does not dictate the motives behind marriage.
What are the grounds for fraud that can annul a marriage?	The Family Code specifies limited grounds for fraud, including non-disclosure of a prior conviction, concealment of pregnancy by another man, concealment of a sexually transmitted disease, or concealment of drug addiction, alcoholism, or homosexuality.
What was the court’s final decision in this case?	The Supreme Court granted the petition, annulling the Court of Appeals’ decision and dismissing the civil case, effectively upholding the validity of the marriage between Albios and Fringer.
What is the practical implication of this ruling?	The practical implication is that marriages entered into for specific purposes, such as acquiring citizenship, are not automatically void if all legal requirements are met. This protects the institution of marriage from being easily invalidated.

In conclusion, the Supreme Court’s decision underscores the importance of upholding the institution of marriage while recognizing the complexities of human motives. The ruling ensures that marriages entered into with proper consent and adherence to legal requisites are not easily invalidated based on ulterior purposes, thereby protecting the sanctity of marriage under Philippine 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: Republic vs. Albios, G.R. No. 198780, October 16, 2013