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Comments on Senate Bills

NOS. 67, 288, 356 & 504

JD-3B CLASS WILLS AND SUCCESSION

ATTY. KAMILLE DEANNE LAGASCA-MAHIG


INTRODUCTION

It is true that the marriage is an inviolable social institution.


Entering into the contract of marriage is a right recognized by
the state. However, in every right there is corresponding
obligation. There should be love, respect, support and other
factors that ensure a happy and healthy relationship. If there
are violations of these obligations, that sometimes even
endangers the life of the couple, it is just for the state to also
recognize their right to end the contract and exit the failed
relationship. Its easy to fall in love, but staying in love is hard

Comments on Senate Bills work. We should look into a deeper sense that what these bills
protect is not just the marriage contract but most importantly,
NOS. 67, 288, 356 & 504 the harmonious relationships of the families. Article 1 of the
Family Code states that “Marriage is a special contract of
permanent union between a man and a woman entered into in
accordance with law for the establishment of conjugal and
family life. It is the foundation of the family and an inviolable
social institution whose nature, consequences, and incidents
are governed by law and not subject to stipulation…XXX.”
Permanent union means it cannot be separated, the parties to
the marriage are decided and committed to make the
Introduction

relationship last no matter what. The real essence of marriage


is for permanence, allowing the lax grounds in the absolute
divorce bill to severe marriage tie is to go against the main
intention of the lawmakers of our family code that marriage is
for a lifetime.Moreover, Article 2, Section 12 of our present
Constitution states that “The State recognizes the sanctity of
family life and shall protect and strengthen the family as a
basic and autonomous social institution.” The word “sanctity”
means marriage is sacred, it is not merely a contract, but it
involves God and a covenant between husband and wife.
Covenant means I will be a good husband/wife to you even if
you don’t, that I will take care of you no matter what, that I will
fight for this marriage through thick and thin, that I will fulfil
my obligation to you as husband/wife even if at times I don’t
feel like to. The mindset in marriage is to be selfless, it is giving
your best to the other half to make her/him flourish and make
the marriage work. The goal is not to fight in the marriage but
to fight for the marriage.
INTRODUCTION

The passage of these bills into law will run counter to the
provisions on marriage of our Constitution which, Filipinos
being predominantly Christian, embodies our culture and
belief on marriage.

It will give meaning to marriage as transactional, that is, ‘I’ll


stay if you are able to make me happy by giving me this and
that, and if you no longer fullfill my needs and make me happy,
I’am out of this, we’re done. Instead of encouraging the parties

Comments on Senate Bills to fight for their marriage and be reconciled they are now
tempted not to try their best to make the marriage work and

NOS. 67, 288, 356 & 504 just give up. Jumping from one relationship to another and so
on, thinking that once they got out of their current relationship
the succeeding marriages would be better and make them
happier, But one study proved otherwise, According to the
study of Wallerstein J.S., and Blakeslee S. 2004 entitled Second
chances: Men, women, and children a decade after divorce, it
demonstrated that those who were unhappy in their marriage
when first surveyed, but remained married, were likely to have
an improved relationship and be happier five years later than
Introduction

those who divorced


(www.ncbi.nlm.nih.gov/pmc/articles/PMC4240051/#C19).Going
through the process of having it declared judicially valid and
enforceable by our courts is not injustice and inequality; rather
it is giving high degree of importance and recognizing the
sanctity of the contract of marriage by the State in putting it
(dissolution of marriage) within the control of the court,
precisely to protect and secure our rights.The purpose of
succession is to preserve and protect the property of a
deceased person, to transfer it to its relatives properly entitled
and to prevent its transfer to strangers which is against the
intention of the deceased. This paper contains the comments
of the Class regarding the possible effects of the provisions of
the bills regarding the successional rights of a person affected
upon their effectivity and passage. The bills contain topics
about divorce, recognition of divorce decree and the effects of
church annulment decree.
SENATE BILL NO. 67

AN ACT RECOGNIZING THE FOREIGN


DECREE OF TERMINATION OF MARRIAGE
AND ALLOWING ITS SUBSEQUENT
REGISTRATION WITH THE PHILIPPINE
CIVIL REGISTRY, AMENDING FOR THE
PURPOSE OF EXECUTIVE ORDER NO. 209,
OTHERWISE KNOWN AS THE FAMILY CODE
OF THE PHILIPPINES

This provision of the proposed bill should be taken into


Comments on Senate Bills consideration because it may prejudice or burden the legitime
of the compulsory heirs because it gives the option to the
NOS. 67, 288, 356 & 504
spouses in the recognition of the presumptive legitime of their
common children. I suggest that the recognition and delivery
of the presumptive legitime must be in accordance with the
Family Code. Under the Family Code, the final judgment shall
provide for the liquidation, partition and distribution of the
properties of the spouses, the custody and support of the
common children, and the delivery of their presumptive
legitimes, unless such matters had been adjudicated in
Collective Comments

previous judicial proceedings.As to the effect of Senate Bill No.


67 on Successional Rights, it provides that any agreement on
the liquidation, partition and distribution of the properties of
the spouses, the custody and support of common children, the
delivery of their presumptive legitimes included in the decree
of termination of marriage shall be recognized. In the absence
thereof, the provisions of the Family Code shall be in force. As a
rule, the testator cannot deprive the compulsory heirs of their
legitimes. And as an exception, there must be a valid
disinheritance. Valid disinheritance must be made in a will,
which is for a legal cause and said cause must be stated and
proved by evidences.Disinheritance, in case presented in the
decree, cannot be agreed upon by the parties. It is not
automatic in the sense that evidence must be presented first
before disinheritance may be substantiated. Also, it must be
for a valid and sound cause. The agreement on the delivery of
their presumptive legitimes in the decree, provided for by this
bill, may prejudice and impair the right of other heirs of the
testator to inherit their part of the legitime. Those compulsory
heirs may be deprived of their legitimes by way of excluding
SENATE BILL NO. 67

AN ACT RECOGNIZING THE FOREIGN


DECREE OF TERMINATION OF MARRIAGE
AND ALLOWING ITS SUBSEQUENT
REGISTRATION WITH THE PHILIPPINE
CIVIL REGISTRY, AMENDING FOR THE
PURPOSE OF EXECUTIVE ORDER NO. 209,
OTHERWISE KNOWN AS THE FAMILY CODE
OF THE PHILIPPINES

them to inherit or by illegal or unlawful disinheritance having


Comments on Senate Bills no lawful or valid cause accompanied by evidence as being
provided for by law, or in any other ways as to be agreed upon
NOS. 67, 288, 356 & 504
by the parties in the decree.On the successional rights of a
child, both bills seek to secure that the legitime is not
impaired. It gives mandate that upon the grant of a final
divorce decree said presumptive legitime shall be computed
while the delivery of the same is at the option of the spouses.
However, since delivery is optional and the children’s
hereditary rights commences only at the moment of the
decedent’s death, the computed and supposed legitime at the
Collective Comments

time of divorce might be utilized for the benefit the second


family and so on. As a consequence, the actual legitime
received by the children of the previous marriage might be less
than the amount earlier determined which is prejudicial to
them. There should be a provision that the actual legitime of a
child of the previous marriage shall not be less than what is
computed on the date of grant of the final divorce decree, or
that it should be held in trust to secure his share of the
inheritance.The provisions in these bills are in a way favorable
and adventageous to the children because they provide
protection about their legitimes and maintenance of their
legal status. However, some issues may arise regarding the
validity of the partition and distribution of the properties since
the recognition and delivery of the presumptive legitime shall
be at the option of the spouses. This right to choose by the
spouses may lead to disinheritance of some of the compulsary
heirs without valid and just cause accompanied by evidence as
required by law.As a consequence, the Filipino citizen who was
divorced must be removed from legal inheritance to everything
except properties and interests that are primarily located in t
SENATE BILL NO. 67

AN ACT RECOGNIZING THE FOREIGN


DECREE OF TERMINATION OF MARRIAGE
AND ALLOWING ITS SUBSEQUENT
REGISTRATION WITH THE PHILIPPINE
CIVIL REGISTRY, AMENDING FOR THE
PURPOSE OF EXECUTIVE ORDER NO. 209,
OTHERWISE KNOWN AS THE FAMILY CODE
OF THE PHILIPPINES

he Philippines. While the divorce divest the Filipino citizen of


Comments on Senate Bills their inheritance in foreign countries, the inheritance of the
Citizen must stay when it comes to Philippine properties so
NOS. 67, 288, 356 & 504
that they are not prejudiced when they are divorced in foreign
courts, an act that while it is legal, it violates one of the
principle of the constitution. The Children of such marriage
must remain legitimate and for the purpose of inheritance, be
considered as such even though they are divorced, this should
not only be limited to Philippine properties, as it would also
protect the interest of the child from a foreign ruling or their
tolerance of divorce.The provisions with regards to the
Collective Comments

successional rights or presumptive legitime, custody and


support of children in the senate is also affected since the
Judicial proceeding will no longer be needed and the court can
no longer interpret or validate the validity of the provisions of
the decree in the proceeding, we cannot guarantee the
protection they will get in the agreement from decree of
termination of marriage.

The Supreme Court should amend the rules of court so that the
successional rights of the children after termination of
marriage between husband and wife will not be compromised.
If this bill will be approved then it will make the children suffer
if there is no concrete rule that will support their successional
rights after the termination of marriage of their parents. To
make this bill beneficial to children not on their parents then
there is a need for the Supreme Court to provide a rule that will
support and ensure that children will inherit some properties
of their parents after the termination of marriage.
SENATE BILL NO. 67

AN ACT RECOGNIZING THE FOREIGN


DECREE OF TERMINATION OF MARRIAGE
AND ALLOWING ITS SUBSEQUENT
REGISTRATION WITH THE PHILIPPINE
CIVIL REGISTRY, AMENDING FOR THE
PURPOSE OF EXECUTIVE ORDER NO. 209,
OTHERWISE KNOWN AS THE FAMILY CODE
OF THE PHILIPPINES

Successional rights or its effects on liquidation, partition and


Comments on Senate Bills distribution of the properties, the passage of this bill to a law
may shorten the period of processing as well, depending on
NOS. 67, 288, 356 & 504
how long such should be registered in the Philippine Civil
Registry, as compared to seeking a Judicial Recognition. This is
in consideration of the fact that where the termination of
marriage is not recognized, there shall be no partition pending
the judicial recognition if the Philippine laws shall apply to the
partition of the properties. However, this may further be
discussed in order to ensure that there be a safeguard for the
successional rights of the Filipino spouse and their children.
Collective Comments
SENATE BILL NO. 288

AN ACT INSTITUTING ABSOLUTE DIVORCE


AND DISSOLUTION OF MARRIAGE IN THE
PHILIPPINES
_________________________________________

SENATE BILL NO. 356

AN ACT INSTITUTING ABSOLUTE DIVORCE


IN THE PHILIPPINES

Comments on Senate Bills In an article posted by Divorce Law Philippines on their page,
they compared divorce to an umbrella because when lots of
NOS. 67, 288, 356 & 504
people bring umbrellas, chances are it will rain, but it does not
mean that umbrellas cause rain to fall. Just like in divorce,
divorce is a recognition of a failed marriage, but it does not
cause marriages to fail.The contention of the proponent of the
bill is that separated couples are increasing because of the
denial of legal remedies to dissolve their existing marriage. The
negative and bad effects of this to women who more often than
not are the victims of abuses inside marriage and that this act
Collective Comments

will give them a fresh start to an improve well-being. On


children, it creates an atmosphere not conducive for the
development of their well-being as well because of their
witnessing and will affect their psychological, social, emotional
development.

These bills are advantageous for the heirs of the testator


because it provides a decree containing provisions for the
protection of their legitime. However, these two (2) bills have
provisions which could lead to a problem when it comes to the
entitlement of the children’s legitime. Various cases may be
filed questioning the validity of the partition and distribution
of their parents’ properties and some cases may have issues
concerning disinheritances because the option given to their
parents, by these provisions may lead to disinheritance of the
other compulsory heir, without proving a valid and lawful
cause in evidence as being required by the law.I strongly agree
with the principal author of Senate Bill No. 356, Senator Risa
Hontiveros, that the absence of a divorce law has had
disproportionate effects on women who are more often the
SENATE BILL NO. 288

AN ACT INSTITUTING ABSOLUTE DIVORCE


AND DISSOLUTION OF MARRIAGE IN THE
PHILIPPINES
_________________________________________

SENATE BILL NO. 356

AN ACT INSTITUTING ABSOLUTE DIVORCE


IN THE PHILIPPINES

Comments on Senate Bills victims of abuse within marriages, and who are forced to
remain in joyless and unhealthy unions because of the dearth
NOS. 67, 288, 356 & 504
of legal options. In an article published by Philippine Star, it
reminded the Filipino people to defend and nurture the Filipino
family, by all means, but there should also be an
acknowledgement as to the reality about all human
relationships that sometimes we do not really know the person
we chose to share our life with. Senate Bill No. 356 is a bill
which will give opportunities for victims of violence within
marriages to have a new beginning.As to the effects of Senate
Collective Comments

Bill No. 288 on Successional Rights, I strongly agree with


Paragraph (h) of Section 11, Senate Bill No. 288 which provides
that the effects on the divorced spouses with respect to
intestate succession, testamentary dispositions, donations and
insurance provisions on beneficiaries in accordance with the
Family Code of the Philippines and jurisprudence will be
observed; and Paragraph (i) of Section 11, Senate Bill No. 288
which provides that the legitimate and adopted children of
divorced parents shall retain their legal status and legitimacy;
a child conceived or born within 300 days after the filing of a
petition for absolute divorce shall be considered legitimate,
unless the ground for divorce is the marital infidelity of the
wife. These provisions give hope and a chance to live again not
only for the spouses but for their children. However, Paragraph
(c) of Section 11, Senate Bill No. 288 should be taken into
consideration. It provides that the recognition and delivery of
the presumptive legitime of the common children shall be at
the option of both spouses. The presumptive legitime shall be
computed as of the date of the finality of the decree of
absolute divorce.
SENATE BILL NO. 288

AN ACT INSTITUTING ABSOLUTE DIVORCE


AND DISSOLUTION OF MARRIAGE IN THE
PHILIPPINES
_________________________________________

SENATE BILL NO. 356

AN ACT INSTITUTING ABSOLUTE DIVORCE


IN THE PHILIPPINES

Comments on Senate Bills The partition and distribution of the properties of the spouses
and the delivery of the children's presumptive legitime upon
NOS. 67, 288, 356 & 504
the option of the spouses shall be recorded in the appropriate
civil registry and registries of property, otherwise the same
shall not affect third persons. Paragraph (c) of Section 11,
Senate Bill No. 288 may prejudice or burden the legitime of the
compulsory heirs because it gives the option to the spouses in
the recognition of the presumptive legitime of their common
children. I suggest that the recognition and delivery of the
presumptive legitime must be in accordance with the Family
Collective Comments

Code.Such provision of the proposed bill should be taken into


consideration because it may prejudice or burden the legitime
of the compulsory heirs because it gives the option to the
spouses in the recognition of the presumptive legitime of their
common children. I suggest that the recognition and delivery
of the presumptive legitime must be in accordance with the
Family Code. Under the Family Code, the final judgment shall
provide for the liquidation, partition and distribution of the
properties of the spouses, the custody and support of the
common children, and the delivery of their presumptive
legitimes, unless such matters had been adjudicated in
previous judicial proceedings. On matters of legitime,
successional rights, legal status of children, liquidation or
separation of property of the spouses, almost all provisions are
the same except for the period of revocation of donation and
additional support for the non-gainfully employed spouse
provided in Senate Bill no. 288 and the part that Senate Bill no.
356 specifically mentioned that the paraphernal or exclusive
properties of either spouses be excluded from the equal
division of the Conjugal partnership or absolute community if
SENATE BILL NO. 288

AN ACT INSTITUTING ABSOLUTE DIVORCE


AND DISSOLUTION OF MARRIAGE IN THE
PHILIPPINES
_________________________________________

SENATE BILL NO. 356

AN ACT INSTITUTING ABSOLUTE DIVORCE


IN THE PHILIPPINES

Comments on Senate Bills there be no marriage settlement prior to their celebration of


marriage.
NOS. 67, 288, 356 & 504
Divorce must not be withheld to spouses who no longer want
to be partners to each other. In this instance of divorce, the
state is within its right to protect the institution of the
marriage, however if there are irreconcilable reasons to
continue the marriage, they should not force them to remain
married and seek to protect the children’s interest instead. In
this case, the succession of the parties will cease to exist upon
Collective Comments

divorce, but their children must remain an heir for their


properties even if they obtained such property after the
separation.As to the similar provisions to Senate Bill no. 288,
again, I see no reason to negate the similar provisions
regarding this matter, but it may be further discussed to
safeguard the rights of the children born out of the terminated
marriage. Because as to the provision, the recognition and
delivery of recognition of the presumptive legitime shall be at
the option of both spouse and shall be recorded in the
appropriate civil registry and registries of properties and shall
be computed as the date of finality of the decree of absolute
divorce. And both bills still noted that the effects on intestate
succession, testamentary dispositions, donations and
insurance provision on the beneficiaries shall still be in
accordance with the Family Code and Philippine Jurisprudence
will be observed.
SENATE BILL NO. 504

AN ACT RECOGNIZING THE CIVIL EFFECTS


OF CHURCH ANNULMENT DECREES

This bill is violative of the separation of the Church and the


State as embodied in our present Constitution. Although the
Church takes part in solemnizing the marriage, it is eventually
the State who has the power to determine the civil status of an
individual. The recognition of decree of termination of
marriage granted by the spouses’ church or religious sect
according to its own canons or precepts, is an encroachment of
Comments on Senate Bills the State’s duty and power to protect the sanctity of marriage.
It gives the churches or religious sects the free hand to
NOS. 67, 288, 356 & 504
determine its own grounds to terminate the marriage which
rightfully belongs to the State alone. Thus, it is
unconstitutional. Moreover, the provision in Sec 2 of which
provides that the status of children in case the ground for the
church annulment decree is not similar to any of the grounds
provided in the Family Code of the Philippines, their common
children born or conceived before the issuance of the church
annulment decree shall be agreed upon by the spouses, is
Collective Comments

discriminatory and prejudicial to the said children. Because


their status is not fixed by the proposed law (whether
legitimate or illegitimate) but dependent upon the agreement
of the spouses, they will be unsure of the portion of their
legitime. Their supposed to be reserved share of the
inheritance will be dependent on their parents’ wishes.

Not only as a devout Catholic but also as a law student, I agree


with the principal author of Senate Bill No. 504, Senator Pia
Cayetano, that the enactment of this bill will provide equality
in the eyes of the law for marriages that are celebrated or
annulled under other religious laws.However, as to the effects
of Senate Bill No. 504 on Successional Rights, specifically, as to
the status of children of marriages subject of the church
annulment decree, should be taken into consideration. Sec. 2
of the said bill states that in case the ground for the church
annulment decree is not similar to any of the grounds provided
in the Family Code of the Philippines, their common children
born or conceived before the issuance of the church annulment
decree shall be agreed upon by the spouses, and embodied in a
SENATE BILL NO. 504

AN ACT RECOGNIZING THE CIVIL EFFECTS


OF CHURCH ANNULMENT DECREES

public document. In case no agreement is met, the provisions


of the Family Code of the Philippines shall be in force. Such
provision may prejudice the children as to their status which
also may affect their successional rights because the legitime
of an legitimate child and illegitimate child are not the same. If
the discretion will be given to the spouses, there is a tendency
that the legitime of the heirs will be burdened. I suggest that
Comments on Senate Bills the provisions of the Family Code of the Philippines must
governed the effects as to the status of children of marriages
NOS. 67, 288, 356 & 504
subject of the church annulment decree, whether or not there
is an agreement between the spouses.

Furthermore, Sec. 3 of the proposed bill provides that the


liquidation, partition and distribution of the properties of the
spouses, the custody and support of the common children, and
the delivery of their presumptive legitimes shall be agreed
upon by the spouses and embodied in a public document. In
Collective Comments

case no agreement is met, the provisions of the Family Code of


the Philippines shall be in force. The abovementioned
provision should be also taken into consideration. It states that
the recognition and delivery of the presumptive legitime of the
common children shall be at the option of both spouses. I
suggest that the recognition and delivery of the presumptive
legitime must be in accordance with the Family Code even if
there is agreement between the spouses. Under the Family
Code, the final judgment shall provide for the liquidation,
partition and distribution of the properties of the spouses, the
custody and support of the common children, and the delivery
of their presumptive legitimes, unless such matters had been
adjudicated in previous judicial proceedings.

As I repeatedly assailed in previous comments, disinheritance


may be established when there is an agreement thereto,
without complying with the requisites provided for by our laws.
There is protection of the heirs of their legitimes however, it is
not that totally and absolutely in its sense because there was
SENATE BILL NO. 504

AN ACT RECOGNIZING THE CIVIL EFFECTS


OF CHURCH ANNULMENT DECREES

an agreement thereto, which may impair and prejudice the


rights of the heirs leading to violation of due process of law.

In succession, legitimate and illegitimate children have their


rights to inherit with a certain percentage. The abovestated
provision states that the delivery of their presumptive
legitimes shall be agreed upon by the spouses. The aggrieved
Comments on Senate Bills spouse will not agree that the illegitimate child will inherit
from their conjugal properties, but if the Family code of the
NOS. 67, 288, 356 & 504
Philippines will be referred to in regard to the Property
relations of the spouses, then all legitimes can have their
share. Also, there could be a conflict of interest and unequal
division of shares among the children if the disposition will be
between the spouses. Unequal division may arise if there is a
favorite son or daughter, hence, such is not fair to the other
children. Also, the law has reserved the rights of the heirs,
hence, the law shall be the basis on successional rights and not
Collective Comments

merely the agreement of the spouses. One of the spouses may


also want to have a legacy or a devise, and if one of the parties
will not agree to it, the spouse who wants to donate inter vivos
rights may be prejudiced if the disposition will be based on the
spouses’ agreement.Although it emphasizes under Section 3
that the liquidation, partition and distribution of the
properties of the spouses, the custody and support of the
common children, and the delivery of their presumptive
legitimes shall be agreed upon by the spouses, the security of
the legitimate children do not have any assurance because the
subsequent marriage of one or each spouse because this bill
allows it might prejudice the legitimate children, also there is a
big possibility that one or each spouse will have an illegitimate
children. The proposed bill also gives the option to the spouses
as to the status of their children and their legitimes. If this will
be the system of law with regards to status of children and
their legitimes, we might as well go back to the system during
the time of BARUK AND SEGUNDINA.
CONCLUSION

It makes it easier to circumvent the Philippine law on marriage,


as it would be easier to terminate marriage by Filipinos even
without the grounds provided for in the Family Code. What the
spouse, who wants to quit marriage, will have to do is to
acquire a foreign citizenship in countries where it is easy to
become nationals and where divorce is easy and legal. In this
case, the sanctity of marriage and family relations which the
Constitution and the Family Code seek to protect can be easily
severed. It will be subject to abuse, Filipinos will easily enter
into marriage without thinking, knowing they have a way
Comments on Senate Bills out.Granting that the Senators are pushing the approval of the
bill in good faith, however, sad to say, both Senators failed to
NOS. 67, 288, 356 & 504
discount the long term effect of the divorce bill not only upon
the woman whom they are trying to defend her welfare but as
well as the welfare of the child or children born to that
marriage. Needless to say, marriage is a sacred vow and our
state primarily gives emphasis that family is the basic
institution of our society hence, it should be upheld at all
times. Subsequently, provisions of the present Family Code
already provided access in the nullity of marriage in extreme
cases where union is no longer irreparable. Liberalizing the
dissolution of marriage in our country in the form of divorce
and by making it less expensive is not the solution. Going
through the process of having it declared judicially valid and
Conclusion

enforceable by our courts is not injustice and inequality; rather


it is giving high degree of importance and recognizing the
sanctity of the contract of marriage by the State in putting it
(dissolution of marriage) within the control of the court,
precisely to protect and secure our rights. What the bill is
trying to achieve is to create a shortcut, a wrongful notion as a
tool to woman empowerment. The dissolution of the first
marriage or prior marriage is not, will not, and cannot
guarantee a better and successful subsequent marriage. Such
power would amount to crossing the line of separation
between church and state. To argue that Muslim churches
exercises such power so other churches is clearly impartial as
Muslim law is solely based in their religion while the
constitution is clearly drafted from generally accepted
principles and logical, sound reason. To argue that churches,
since given the power to solemnize marriage, must also be
CONCLUSION

given power to annul the same is without merit. Besides, the


judgment of an adjudicator is based on laws which are derived
from logic and with basis while those of the church are based
solely on morale.

As we watch the new generation walk in our present day, we


must teach them the importance and sanctity of marriage
however, we just cannot let one suffer from a failed marriage.
Most importantly, we should not allow one to take the burden

Comments on Senate Bills of staying in an abusive and distressing marriage. Remarrying


is only an option, the important thing to consider here is the
freedom from abuse and choosing healthier well being than
NOS. 67, 288, 356 & 504
staying stressed and miserable. Ask yourself, would you let
your beloved child stay in a bad marriage? We bet not!
Conclusion

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