- Petitioner
- Estrellita Juliano-Llave
- Respondent
- Republic of the Philippines
- Citation
- G.R. No. 169766
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Del Castillo, J.
- Decided
- March 30, 2011
Summary
The Supreme Court affirmed lower courts' declaration that Estrellita Juliano-Llave's 1993 marriage to Sen. Mamintal A.J. Tamano was void ab initio for being bigamous. Sen. Tamano's 1958 marriage to Zorayda Tamano under the Civil Code remained valid and subsisting when he married Estrellita. The Court ruled that the Civil Code, not the Muslim Personal Laws Code (PD 1083), governed the first marriage since it was celebrated before PD 1083's 1977 effectivity. The Court rejected Estrellita's procedural defenses, finding she was not denied due process despite not filing an answer, as her dilatory tactics caused the delays. Zorayda and her son had standing to challenge the bigamous marriage as injured parties. The decision reinforced that bigamous marriages are void ab initio and that subsequent laws cannot retroactively impair vested marital rights under pre-existing legal frameworks.