Iwasawa v. Gangan
REITERATIONFacts
The Antecedents: Petitioner, a Japanese national, met respondent Felisa Custodio Gangan in 2002. Believing her to be single, he married her on November 28, 2002, in Pasay City. They resided in Japan. In 2009, Iwasawa discovered that Gangan had been previously married to Raymond Maglonzo Arambulo on June 20, 1994. Arambulo died on July 14, 2009. Procedural History: Petitioner filed a petition for declaration of nullity of his marriage to Gangan, asserting it was bigamous. The Regional Trial Court (RTC) of Manila, Branch 43, denied the petition, finding insufficient evidence to prove Gangan's prior valid marriage. The RTC reasoned that petitioner lacked personal knowledge of the prior marriage and Arambulo's death, rendering his testimony and the NSO documents unreliable. The RTC denied petitioner's motion for reconsideration. The Petition: Petitioner seeks review on certiorari under Rule 45 of the Rules of Civil Procedure, arguing that the RTC erred in requiring the testimony of an NSO records custodian. He contends that the marriage certificates and death certificate are public documents, which are self-authenticating and prima facie evidence of their contents. The Office of the Solicitor General concurred, asserting that these public documents, admitted by the prosecution, sufficiently established the nullity of the marriage due to bigamy.
Issue(s)
Whether the testimony of the NSO records custodian was necessary to accord evidentiary weight to the public documents presented. Whether the marriage between petitioner Yasuo Iwasawa and private respondent Felisa Custodio Gangan is null and void due to being bigamous.
Ruling
The Supreme Court granted the petition, set aside the RTC decision and order, and declared the marriage of petitioner Yasuo Iwasawa and private respondent Felisa Custodio Gangan NULL and VOID. The Local Civil Registrar of Pasay City and the National Statistics Office were ordered to make proper entries in the records.
Ratio Decidendi
On the necessity of the NSO records custodian's testimony: The Court held that the RTC erred in disregarding the documentary evidence on the ground that the NSO records custodian did not testify. Certificates of marriage and death issued by the National Statistics Office are public documents. As provided in Article 410 of the Civil Code, books making up the civil register and all documents relating thereto are considered public documents and shall be prima facie evidence of the facts therein contained. Being public documents, they are admissible in evidence even without further proof of their due execution and genuineness. Therefore, proof of authenticity and due execution was not necessary in this case. Furthermore, these public documents deserve evidentiary weight as they constitute prima facie evidence of the facts stated therein, and these facts remained unrebutted. On the nullity of the marriage due to bigamy: The Court found that the documentary exhibits concretely established the nullity of the marriage on the ground of bigamy. The exhibits proved that private respondent was married to Raymond Maglonzo Arambulo on June 20, 1994. She then contracted a second marriage with petitioner on November 28, 2002. Crucially, there was no judicial declaration of nullity of the first marriage at the time of the second marriage. The first marriage was still valid and subsisting when the second marriage was contracted. Raymond Maglonzo Arambulo died on July 14, 2009, and it was only on that date that private respondent's marriage with Arambulo was deemed dissolved. Consequently, the second marriage to petitioner was bigamous and void from the beginning, as provided in Article 35(4) of the Family Code of the Philippines. The private respondent herself admitted in a letter to the Court that she contracted both marriages and that she married petitioner without informing him of her previous marriage due to poverty and joblessness.
Main Doctrine
A marriage contracted without a judicial declaration of nullity of a prior existing marriage is bigamous and void from the beginning. Public documents, such as certificates of marriage and death issued by the National Statistics Office, are self-authenticating and admissible in evidence without further proof of their due execution and genuineness, and they constitute prima facie evidence of the facts stated therein.