FACTS:

Respondent Lea De Leon Castillo (Lea) was first married to Benjamin Bautista on May 25, 1972. On January 6, 1979, Lea married petitioner Renato Castillo. Renato filed a Petition for Declaration of Nullity of Marriage with the Regional Trial Court (RTC) on May 28, 2001, alleging that Lea's first marriage was still subsisting at the time of their marriage. Lea opposed the petition, claiming that her first marriage to Bautista was null and void. She also filed a separate action to declare her first marriage null and void, which was granted by the RTC of Parañaque City. The RTC then declared the marriage between Renato and Lea null and void on the ground of bigamy. Renato filed a motion for reconsideration, which was denied. Both parties appealed the decision to the Court of Appeals (CA), which reversed the RTC decision and upheld the validity of the marriage. Renato filed a Petition for Review on Certiorari with the Supreme Court, seeking to reverse the CA decision.

ISSUES:

1. Whether or not the Court of Appeals was correct in reversing the Regional Trial Court's declaration of nullity of the second marriage.

RULING:

1. The Court of Appeals was correct in holding that the second marriage was valid and reversing the Regional Trial Court's declaration of nullity. The Court agreed with the CA's reasoning that if the first marriage is absolutely null, the party is not prevented from contracting a second marriage without awaiting a final decree of nullity of the first marriage. The CA correctly applied the Civil Code, which was the law in effect when the marriages were celebrated, and which does not require a judicial decree to establish the nullity of a marriage.

PRINCIPLES:

• If a previous marriage is absolutely null, a party is not prevented from contracting a second marriage without awaiting a final decree of nullity of the first marriage.

• The applicable law in determining the validity of a marriage is the law in effect at the time the marriage was celebrated.