FACTS:
Liberty Albios, a Filipina, married a Japanese national, Norihito Motohashi, in Parañaque in 2001. Albios admitted she married him solely for the purpose of acquiring Japanese citizenship, without any real intention of living with him as husband and wife. After gaining Japanese nationality, she filed a petition for declaration of nullity of marriage on the ground that it was void ab initio due to lack of consent and cause.
The RTC granted her petition, declaring the marriage void. The Republic, through the OSG, appealed, arguing that the marriage is valid because marriage for convenience is not among the grounds to declare it void under the Family Code.
ISSUE:
Whether a marriage entered into solely for the purpose of acquiring foreign citizenship is void ab initio.
RULING:
No. The marriage is valid.
Marriage of convenience is not a ground to declare a marriage void under the Family Code. What is essential is that the formal and essential requisites of marriage were complied with. In this case, both parties had legal capacity, consent, and a valid ceremony before an authorized officer. Motive or purpose (even if merely to acquire citizenship) does not affect the validity of marriage if requisites are present.
The Court stressed that it cannot create new grounds for nullity of marriage outside what the law provides.
DOCTRINE:
A marriage entered into for convenience (such as to acquire foreign citizenship) is not void ab initio, provided the essential and formal requisites are present. The purpose or motive of the parties does not affect the validity of marriage.