Mary Elizabeth Mercado v. Rene V. Ongpin

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.