Anaya v. Palaroan

Summary

Aurora Anaya sought to annul her 1953 marriage to Fernando Palaroan, claiming his non-disclosure of a pre-marital relationship with a close relative constituted fraud under Article 85(4) of the Civil Code. The Juvenile & Domestic Relations Court dismissed the case motu proprio, and the Supreme Court affirmed on appeal. The Court held that fraud as grounds for marriage annulment is strictly limited to the three specific circumstances enumerated in Article 86 of the Civil Code: misrepresentation of identity, non-disclosure of previous criminal conviction, and concealment of pregnancy by another man. Non-disclosure of pre-marital relationships falls under 'other misrepresentation or deceit as to chastity' which is expressly excluded by the Code. The Court emphasized that marriage involves public interest, not just private parties, and the law's restrictive approach serves to protect the institution of marriage. Additional fraud allegations raised in plaintiff's reply were deemed improper as new causes of action and were time-barred.