Sally Go-Bangayan v. Benjamin Bangayan, Jr.

Summary

This case involved Benjamin Bangayan Jr.'s petition to declare his purported marriage to Sally Go-Bangayan null and void and to partition their acquired properties. Benjamin was validly married to Azucena Alegre when he cohabitated with Sally from 1982-1994. Their March 7, 1982 marriage ceremony was simulated, conducted without a valid marriage license and never registered. The Supreme Court affirmed that the marriage was null and void ab initio and non-existent, applying Article 35 of the Family Code for marriages without license and Article 1409 of the Civil Code for simulated contracts. The Court applied Article 148 of the Family Code governing property relations of cohabiting parties, ruling that only properties acquired through actual joint contributions should be co-owned. The decision clarified the distinction between void marriages and non-existent marriages, and established important precedent for property rights of unmarried cohabiting couples under Philippine family law.