Introduction

In Philippine family law, an annulment or declaration of nullity case does not truly end when the judge reads the decision in court or when a party receives a copy. A crucial post-judgment step remains: obtaining a Certificate of Finality (sometimes called an Entry of Judgment) and then recording the decree with the Local Civil Registrar (LCR) and the Philippine Statistics Authority (PSA). Many people ask whether there is a deadline or “expiration” for securing this Certificate of Finality. The short answer in Philippine practice is: there is generally no strict expiration period for requesting the Certificate of Finality, but delays create serious practical and legal consequences in implementing the decision and in remarrying.

This article explains what a Certificate of Finality is, when it is issued, whether there is a time limit, and why acting promptly matters.

1. What Is a Certificate of Finality?

A Certificate of Finality is a document issued by the court certifying that a judgment has become final and executory—meaning:

The losing party did not appeal within the allowed period; or
Any appeal has been resolved and no further review is available.

Courts issue this certificate under the Rules of Court after finality sets in. In family cases (annulment, declaration of nullity, legal separation), the certificate is usually paired with or followed by an Entry of Judgment and a Decree of Annulment / Decree of Absolute Nullity.

Key point: A decision that is not yet final cannot be implemented. Finality is what “activates” the right of the parties to treat the marriage as annulled/void in law and in official records.

2. Decision vs. Decree vs. Certificate of Finality

People often mix these up. They are different stages:

Decision/Judgment – the court’s ruling granting or denying annulment/nullity.
Finality – the decision becomes immutable after the lapse of appeal periods (or after appeal).
Certificate of Finality / Entry of Judgment – the court’s formal certification that finality has occurred.
Decree of Annulment / Decree of Absolute Nullity – issued after finality; this is what gets registered with the LCR and PSA.

Without the decree and registration, your PSA marriage record remains unchanged, even if you “won” the case.

3. When Does Finality Happen?

A. If No Appeal Is Filed

Finality generally occurs after the lapse of the appeal period:

Parties receive the decision.
The losing party has a limited time to appeal.
If no appeal is filed in time, the decision becomes final.

B. If There Is an Appeal

Finality occurs only after:

The appellate court resolves the case; and
No further appeal/review is taken within the allowed time.

C. In Annulment / Nullity Cases Specifically

Family cases involve the Office of the Solicitor General (OSG) or prosecutor as representative of the State. The State may appeal. Finality comes only after all state appeal periods lapse or appeals conclude.

4. Is There an Expiration Period to Request the Certificate of Finality?

General Rule: No fixed “expiration” for requesting it

In Philippine procedure, finality is a legal status of the decision, not something that disappears if you don’t ask for a certificate. Once a decision becomes final and executory, it stays final. Courts do not treat the right to request a Certificate of Finality as time-barred by a specific statutory deadline.

So even if years pass, you may still file a motion/request for issuance of Certificate of Finality and Decree.

Why there is no strict expiry:

The certificate is ministerial once finality exists.
Courts keep records and can issue certifications of final judgments long after.
The Rules of Court do not set a deadline for requesting a certificate.

5. But Delays Have Consequences (Practical “Expiration”)

Even if there’s no formal deadline, waiting too long can create major problems.

A. You cannot remarry without decree + registration

Under the Family Code, a party may remarry only after:

A final decision declaring annulment/nullity;
Issuance of the decree; and
Registration of the decree with the LCR/PSA.

If you never secure finality and registration, the PSA record still shows you married, and any new marriage risks being void and potentially criminally risky.

B. Property and custody provisions may be stalled

Annulment/nullity decisions often include rulings on:

Property relations (liquidation of assets)
Child custody/support/visitation
Use of surnames and parental authority

While finality exists regardless of delay, enforcement becomes harder over time, especially if facts change or parties disappear.

C. Records may become harder to retrieve

Courts archive old cases. A long delay may mean:

extra steps to locate files
possible loss/damage of records
longer administrative processing

Not impossible—just more friction.

D. Potential issues with executory obligations

If the decision orders one party to do something (e.g., deliver property, pay support), delay in execution may lead to:

disputes about compliance
new litigation to enforce
arguments about laches (unreasonable delay) in some situations

Laches usually does not reverse finality, but it can complicate enforcement.

6. How to Get the Certificate of Finality (Typical Steps)

Wait for appeal periods to lapse or for appeal resolution.
File a Motion for Issuance of Certificate of Finality and Decree (through counsel).
The court checks:
- proof of service of decision
- dates of receipt
- absence of appeal / final appellate ruling
Court issues:
- Certificate of Finality / Entry of Judgment
- Decree of Annulment / Nullity
Register the Decree with:
- Local Civil Registrar where marriage was recorded
- Local Civil Registrar of the court’s location (common practice)
- PSA (through LCR endorsement)

Only after PSA annotation will your civil status reflect the judgment.

7. Special Notes in Philippine Annulment/Nullity Practice

A. The “State” must be notified

Even post-judgment, family cases often require ensuring that:

OSG/prosecutor received the decision; and
OSG did not appeal.

Proof of notice to the OSG is usually required before finality and decree issuance.

B. Two marriages, two records

If a marriage was recorded in one city but the case was filed elsewhere, registration must be done in:

place of marriage registration, and
PSA central system.

Miss one, and PSA may not annotate properly.

C. Annulment vs. Declaration of Nullity

Annulment = marriage was valid initially but voidable because of a defect (e.g., lack of parental consent for certain ages, fraud).
Nullity = marriage was void from the start (e.g., psychological incapacity, bigamous marriage, absence of essential requisites).

Finality mechanics are basically the same, but the decree title differs.

8. Common Misconceptions

Misconception 1: “The decision is enough.” No. Without finality + decree + registration, you remain “married” in PSA records.

Misconception 2: “If I don’t get a certificate fast, I lose the case.” Finality doesn’t vanish. But delaying implementation can hurt you.

Misconception 3: “The court sends it automatically.” Some courts do, many don’t. Often it requires a motion and follow-through.

Misconception 4: “PSA updates itself after court decision.” PSA only annotates after LCR registration and endorsement.

9. Bottom Line

No strict statutory expiration exists for requesting a Certificate of Finality in Philippine annulment/nullity cases.
Finality, once attained, is permanent.
However, delay has real-world consequences, particularly if you intend to remarry, enforce property rulings, or update civil status records.

10. Practical Advice (General Guidance)

If your case was granted:

Coordinate quickly with your lawyer after receiving the decision.
Track dates of receipt by you, your spouse, and the OSG/prosecutor.
File for finality and decree as soon as legally possible.
Complete LCR and PSA registration without delay.
Keep multiple certified copies of:
- Decision
- Certificate of Finality / Entry of Judgment
- Decree
- PSA annotated marriage certificate

This isn’t just paperwork—it’s what makes the judgment usable in daily life.

Final Thought

In Philippine annulment and nullity cases, the law does not punish you with a ticking “expiration date” for getting a Certificate of Finality. But life does. The longer you wait, the longer your civil status stays frozen, your records stay uncorrected, and your legal freedom to move forward stays out of reach.