Engrace Niñal v. Norma Bayadog

Summary

This landmark case establishes that heirs may challenge the validity of a deceased person's marriage even after death when the marriage is void ab initio. The Supreme Court ruled that Pepito Niñal's second marriage to Norma Bayadog was void for lack of proper marriage license, as the required five-year cohabitation period under Article 76 of the Civil Code must occur when both parties are legally free to marry. Since Pepito's first marriage subsisted during most of the claimed cohabitation period with Norma, the exception to marriage license requirement did not apply. The Court distinguished void marriages from voidable marriages, holding that void marriages can be challenged collaterally at any time, even after death of parties, since they are deemed never to have existed. The decision protects legitimate successional rights while upholding the sanctity of marriage as a legal institution.