Isidro Ablaza v. Republic of the Philippines

Summary

Isidro Ablaza sought to declare void his deceased brother Cresenciano's 1949 marriage to Leonila Honato, claiming the marriage lacked a valid license. Lower courts dismissed the case, ruling Isidro lacked standing as he wasn't a party to the marriage. The Supreme Court reversed, holding that under the old Civil Code regime, a surviving brother with material interest in the deceased's estate may challenge marriage validity if he stands to inherit. The Court distinguished marriages under the old Civil Code from those under the Family Code, noting that A.M. No. 02-11-10-SC's restriction limiting nullity actions to spouses only applies to Family Code marriages. The case was remanded to determine Isidro's status as heir and to implead indispensable parties including the widow and her daughter. This establishes important precedent on standing requirements for marriage nullity actions under different legal regimes.