• This landmark case establishes the jurisdiction of Philippine courts over the annulment of marriages celebrated abroad involving a Filipino citizen. A Filipino husband sought to annul his marriage to his Korean wife, which was solemnized in Korea, on the ground of bigamy. The Supreme Court ruled that Philippine courts have jurisdiction over the case because the marital status of a Filipino citizen is the subject matter (*res*). However, the Court affirmed the dismissal of the case on the merits, finding that the husband failed to present sufficient evidence to prove his wife's alleged prior marriage and noted the husband's own lack of credibility.

• The Parties: Lazaro Rayray, a Filipino citizen, and Chae Kyung Lee, a Korean national.
• The Marriage: The couple married in Pusan, Korea on March 15, 1953.
• The Allegation: Rayray claimed he later discovered a "police clearance" document which, when translated, suggested that Lee was already married to another person before their wedding, making their marriage bigamous.
• The Lawsuit: Rayray filed a complaint for annulment in the Philippines. As Lee was a non-resident with unknown whereabouts, summons was served by publication.

• Lower Court Ruling: The Court of Juvenile and Domestic Relations dismissed the complaint on two grounds: (1) it had no jurisdiction to annul a marriage contracted abroad, and (2) the evidence presented was insufficient to prove the alleged prior marriage.
• Court of Appeals Action: Rayray appealed to the Court of Appeals, which certified the case directly to the Supreme Court because a question of jurisdiction was involved.

• Does a Philippine court have jurisdiction to annul a marriage celebrated abroad between a Filipino citizen and a non-resident alien?
• Did the plaintiff present sufficient evidence to prove that the defendant had a valid, subsisting prior marriage?

The Supreme Court affirmed the dismissal of the complaint, but on different grounds than the trial court.

• On Jurisdiction (YES): The Court ruled that the lower court's conclusion on jurisdiction was erroneous. Philippine courts *do* have jurisdiction. Annulment is an action *in rem* concerning marital status. Since the plaintiff, Rayray, is a Filipino citizen domiciled in the Philippines, the court has jurisdiction over the *res* (the marital tie), regardless of where the marriage was celebrated or the defendant's non-resident status.
• On the Merits (INSUFFICIENT EVIDENCE): The Court affirmed the dismissal because Rayray failed to prove his case. The "police clearance" was unsigned hearsay and not competent evidence of a prior marriage. The defendant's alleged admission was not a confession of marriage, and their official marriage certificate stated she was single. Crucially, the Court found Rayray's own testimony unbelievable, as he admitted to lying on the marriage certificate about his own prior marriage in the Philippines.

• Jurisdiction in Annulment Cases: A Philippine court has jurisdiction to annul a marriage, even one celebrated abroad, as long as at least one of the parties is a Filipino citizen.
• Action *in rem*: An action for annulment of marriage is an action *in rem* because it concerns the marital status of the parties, which is the *res* or subject matter that binds the whole world.
• Summons by Publication: Jurisdiction over a non-resident defendant in an action *in rem* can be acquired through summons by publication.
• Burden of Proof: The party alleging the invalidity of a marriage has the burden of proving such invalidity with clear and convincing evidence.