- Petitioner
- Yasuo Iwasawa
- Respondent
- Felisa Custodio Gangan (A.K.A Felisa Gangan Arambulo
- Citation
- G.R. No. 204169
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Villarama, Jr., J.
- Decided
- September 11, 2013
Summary
Japanese national Yasuo Iwasawa married Filipino Felisa Custodio Gangan in 2002, believing she was single. In 2009, she confessed to having a previous husband who had died. Iwasawa discovered she was previously married to Raymond Arambulo in 1994, who died in 2009. He filed a petition to declare their marriage null and void for bigamy. The RTC denied the petition, ruling insufficient evidence and requiring NSO custodian testimony. The Supreme Court reversed, holding that NSO documents are self-authenticating public documents under Civil Code Article 410, constituting prima facie evidence. The Court declared the marriage null and void as bigamous, since the first marriage was valid and subsisting when the second marriage was contracted, and no judicial declaration of nullity had been obtained.