Jhoeven P.

Guillermo
Legal Research

If we presume that the marriage of Gene to Jane is completely valid, he cannot legally marry his
former girlfriend although his marriage to Jane was annulled. Marriage abroad between Filipino citizens is
solemnized by consular official of the Republic of the Philippines as stated in Article 10 of the Family
Code. Consular officials are representatives of the State. Duties of the local civil registrar are vested upon
them. It follows that; any marriage made in a foreign country must conform to the solemnities under the
law of the Philippines in accordance with Article 17 of the Civil Code.
The decision of England to annul his marriage to Jane is valid in the place where it was executed.
However, their annulment is not recognized in the Philippines because sterility as ground for annulment is
not mentioned in Article 45 of the Family Code which enumerates the grounds for annulment.