Republic v. Court of Appeals
REITERATIONFacts
The Antecedents: Angelina M. Castro filed a petition seeking a judicial declaration of nullity of her marriage to Edwin F. Cardenas, alleging that no marriage license was issued prior to their wedding. The couple was married on June 24, 1970, in Pasay City. Cardenas handled the marriage document processing, and the marriage contract indicated license no. 3196182 was issued in Pasig. The couple did not cohabitate immediately, only doing so in March 1971 when Castro discovered her pregnancy. Their cohabitation lasted four months, and Castro gave birth in October 1971. Castro later sought to regularize her marital status to join her daughter in the United States and discovered through legal efforts that no marriage license had been issued. Procedural History: The Regional Trial Court of Quezon City denied Castro's petition, deeming the certification from the Civil Register of Pasig, which stated that marriage license no. 3196182 could not be located, as inadequate proof of non-issuance. The trial court ruled that the inability to locate the license did not conclusively prove it was never issued. Castro appealed this decision to the Court of Appeals, maintaining that the civil registrar's certification sufficiently established the absence of a marriage license. The Court of Appeals reversed the trial court's decision, declaring the marriage null and void and ordering the cancellation of the marriage contract. The Petition: The Republic of the Philippines, as petitioner, seeks review of the Court of Appeals' decision through a petition for review on certiorari. The Republic argues that the appellate court erred in ruling that the civil registrar's certification of non-issuance, coupled with Castro's uncorroborated testimony, was sufficient to prove the absence of a marriage license. Petitioner contends that these pieces of evidence are insufficient to overcome the legal presumption of a valid marriage and the presumption that the solemnizing officer regularly performed his duties. The core issue presented is whether the documentary and testimonial evidence presented by Castro adequately established the non-issuance of the marriage license.
Issue(s)
Whether the certification issued by the civil registrar is sufficient proof of the non-issuance of a marriage license. Whether the uncorroborated testimony of private respondent Castro, coupled with the certification, is sufficient to establish the absence of a marriage license and thus render the marriage void ab initio. Whether the Court of Appeals erred in disregarding the presumption that the solemnizing officer regularly performed his duties, and whether the absence of a marriage license renders the marriage void ab initio.
Ruling
The petition is DENIED. The Court affirms the decision of the Court of Appeals declaring the marriage between Angelina M. Castro and Edwin F. Cardenas null and void.
Ratio Decidendi
On the sufficiency of the certification of non-issuance of a marriage license: The Court held that the certification issued by the Civil Registrar of Pasig, attesting to a diligent search and inability to find a record of marriage license no. 3196182, is admissible and sufficient proof of its non-issuance. This is sanctioned by Section 29, Rule 132 of the Rules of Court, which allows a written statement from the custodian of official records, after diligent search, that no record of a specified tenor exists. As custodians of public documents, civil registrars are mandated to maintain records of marriage license applications and issuances. The certification, issued by the officer charged with keeping such records, enjoys probative value and, in the absence of any circumstance of suspicion, sufficiently proves that the office did not issue the license. On the sufficiency of testimonial and documentary evidence: The Court found that the documentary evidence (the certification) and the testimonial evidence of private respondent Castro were sufficient to establish the absence of the marriage license. The Court noted that the failure to offer other witnesses was due to the nature of the marriage, described as a "secret marriage" where the parties' relatives were unaware. Furthermore, the husband, Edwin F. Cardenas, was declared in default, and there was no evidence of collusion between the parties. Therefore, Castro's testimony, while uncorroborated by other witnesses, was not a ground to deny her petition, especially given the husband's lack of interest in participating in the proceedings. On the presumption of regularity and the validity of marriage: While there is a presumption that a solemnizing officer regularly performed his duties, this presumption is rebuttable. The Court found that the evidence presented by Castro, particularly the certification from the Civil Registrar, successfully rebutted the presumption of a valid marriage by establishing the absence of a crucial essential requisite – the marriage license. The Court acknowledged that a spurious marriage license might have been presented to the solemnizing officer, but this does not validate a marriage solemnized without a valid license issued by the proper authority. The absence of a marriage license renders the marriage void ab initio under the New Civil Code.
Main Doctrine
A certification from the Civil Registrar, attesting to the diligent search and inability to find a record of a marriage license, is sufficient proof of its non-issuance, thereby rendering the marriage void ab initio for lack of an essential requisite, especially when the other party to the marriage was declared in default and presented no evidence to rebut this.