- Petitioner
- Mary Elizabeth Mercado
- Respondent
- Rene V. Ongpin
- Citation
- G.R. No. 207324
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Leonen, J.
- Decided
- September 30, 2020
Summary
This case involves a petition for moral and exemplary damages arising from a bigamous marriage. Ongpin married Mercado believing his first marriage was dissolved by his first wife's US divorce, but later discovered the divorce was invalid because she was still Filipino. When Ongpin filed for nullity of his second marriage, Mercado claimed damages alleging bad faith. The Supreme Court denied her claim, holding that malice or bad faith must be proved for Article 19 Civil Code violations. The Court found no evidence that Ongpin deliberately contracted the second marriage knowing his first was still valid, and noted that Mercado herself knew of potential issues with the divorce validity as early as 1992 but took no protective action. The decision reinforces that good faith is presumed and bad faith must be proven by clear and convincing evidence in damage claims based on abuse of rights.
Intellegal Wiki · Key Holding
To recover damages under Article 19 of the Civil Code, malice or bad faith must be proved; a party who knew of a potential legal infirmity yet took no action cannot later claim damages.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.