Sujatha v. Jose Augustine (1994)

The petitioner, a Hindu by birth, was taken through a baptism ceremony and then a church marriage with a Latin Catholic man. She later sought a declaration that the marriage was void, alleging fraud and saying the baptism and marriage were not as per Canon Law. The Court held that mere baptism ritual is not enough; one must truly believe and profess the Christian faith. As she never became a Christian in faith, the marriage between a baptized Christian and a non-baptized person was void (Canon 1086).

• Conversion & Faith: Baptism by itself is not enough; a person must truly believe in and profess the Christian faith.
• Canon 1086: A marriage between a baptized Christian and a non-baptized person is void, unless proper dispensation exists.
• Proof of Fraud: Allegations of fraud/undue influence must be proved with reliable evidence; mere assertions will not suffice.

The Court did not find reliable proof of fraud or undue influence. However, it emphasized that conversion requires true faith and profession. There was no evidence of catechumenate, instruction, or intention to live as a Christian. The “baptism” looked like a mere formality before marriage. Therefore, the petitioner never became a Christian in faith. A union between a baptized Christian and a non-baptized person is void—so the marriage was declared void.

1. Faith over Form: Conversion needs genuine belief and profession; ritual alone is insufficient.
2. Canon 1086 Control: Baptized–non-baptized marriage is void unless proper dispensation is proven.
3. Proof Standard: Fraud/undue influence must be strictly proved.

The decision draws a bright line between ceremony and belief. For marriages under church law, true conversion is a matter of faith plus process (instruction, intent), not a tick-box ritual. It protects the integrity of religious sacraments and clarifies when such marriages are legally valid.

• Baptism alone does not prove conversion—faith and profession are essential.
• Without true conversion, a church marriage with a non-baptized person is void.
• Fraud/force must be backed by clear evidence.

Mnemonic (FAITH): Faith needed • Alone baptism not enough • Instruction/catechumenate absent • True profession required • Holy marriage void without it.

1. Spot if conversion was ritual or real (belief + instruction).
2. Apply Canon 1086 on baptized vs non-baptized marriages.
3. Conclude on validity and remedy (declaration of nullity).

Catechumenate

Period of instruction and preparation before baptism and full initiation into the Christian faith.

Canon 1086

Church rule that a marriage between a baptized and a non-baptized person is invalid without dispensation.

Profession of Faith

A sincere declaration and practice of belief—beyond ceremony alone.