People v. San Juan
REITERATIONFacts
The Antecedents: The accused, Domingo San Juan, a minister of the National Evangelical Church of the Philippines, was charged with performing a marriage ceremony where one of the contracting parties was under the age of consent. The information was initially filed against the spouses, two witnesses, and the minister. The case was dismissed against the witnesses and spouses due to their use as government witnesses or subsequent parental consent, respectively. Procedural History: The Court of First Instance of Manila convicted the accused, Domingo San Juan, the minister who performed the ceremony. The Petition: The accused appealed the judgment of conviction.
Issue(s)
Whether the minister who solemnized a marriage where one party was under the age of consent can be held criminally liable under Article 479 of the Penal Code. Whether the minister's good faith and reasonable investigation into the ages of the contracting parties constitute a valid defense.
Ruling
The judgment of conviction is reversed, and the accused is acquitted of the crime charged. The Court held that the minister acted in good faith and without criminal intent, having conducted a reasonably satisfactory investigation into the ages of the contracting parties as required by law.
Ratio Decidendi
On the liability of the minister for solemnizing a marriage where one party was under the age of consent: The Court held that a minister solemnizing a marriage may plead good faith in defense to an action brought against him under Article 479 of the Penal Code. The Court reasoned that there is no reason why the rule applicable to the persons married, who may be excused from criminal prosecution if they acted in good faith and without knowledge that the other was under the age of consent, should not be alike applicable to the person performing the ceremony. It is easier to deceive an officiating clergyman as to the ages of the parties than to deceive either of the spouses. The law, through General Orders, No. 68, authorizes the officiating clergyman to determine the fact of age or nonage upon the testimony of witnesses, and he is given the authority to examine parties and witnesses on oath. Therefore, a wrong determination of that question, made in good faith, should not lead to criminal prosecution. On whether the minister's good faith and reasonable investigation constitute a valid defense: The Court found that the accused acted in good faith and without criminal intent. While there was some evidence tending to show the minister did not act in good faith, the Court found difficulty in establishing this from the testimony of witnesses released from prosecution, which is subject to suspicion. The written statements prepared by the accused at the time of the ceremony, signed and sworn to by the parties and witnesses, contained requisites essential to a valid declaration under General Orders, No. 68, despite the oath not being in the prescribed form. The Court concluded that even if the marriage was illegal and the subsequent consent of the parent did not relieve the defendant of liability, the accused acted in good faith and made the required investigation in a reasonably satisfactory manner, thus his conviction could not stand.
Main Doctrine
A minister solemnizing a marriage is not criminally liable under Article 479 of the Penal Code if he acted in good faith and without criminal intent, having conducted a reasonably satisfactory investigation into the ages of the contracting parties as required by law, even if the marriage was subsequently found to be illegal.