Nenita Bienvenido v. Hon. Court of Appeals

Summary

This case involved a property dispute between Luisita Camacho, who claimed to be the surviving spouse of Aurelio P. Camacho, and Nenita Bienvenido, who had cohabited with Aurelio for 20 years and received the disputed property through sale. The Supreme Court ruled that Aurelio's marriage to Luisita was bigamous and void since his previous marriage to Consejo Velasco was still subsisting when he married Luisita in 1962. The Court held that the burden was on respondents to prove the marriage was valid under the exceptions in Art. 83 of the Civil Code, which they failed to do. Since there was no valid marriage between Aurelio and Luisita, there was no conjugal property to speak of. The sale of the property to Nenita was declared valid, being supported by proper documentation and executed during their long cohabitation. The decision established important precedents on burden of proof in challenging marriage validity and protection of property rights of cohabitants when marriages are subsequently declared void.