Anaya vs Palaroan

Anaya vs. Palaroan

36 SCRA 97

FACTS:

Aurora Anaya and Fernando Palaroan were married in 1953. Palaroan filed an action for
annulment of the marriage in 1954 on the ground that his consent was obtained through force
and intimidation. The complaint was dismissed and upheld the validity of the marriage and
granting Aurora’s counterclaim. While the amount of counterclaim was being negotiated,
Fernando divulged to her that several months prior to their marriage, he had pre-marital
relationship with a close relative of his. According to her, the non-divulgement to her of such
pre-marital secret constituted fraud in obtaining her consent. She prayed for the annulment
of her marriage with Fernando on such ground.

ISSUE: Whether or not the concealment to a wife by her husband of his pre-marital
relationship with another woman is a ground for annulment of marriage.

HELD:
The concealment of a husband’s pre-marital relationship with another woman was not one of
those enumerated that would constitute fraud as ground for annulment and it is further
excluded by the last paragraph providing that “no other misrepresentation or deceit as to..
chastity” shall give ground for an action to annul a marriage. Hence, the case at bar does not
constitute fraud and therefore would not warrant an annulment of marriage.