Salgado v. Anson
REITERATIONFacts
The Antecedents: Luis Anson filed a complaint seeking the annulment of three Unilateral Deeds of Sale and a Deed of Extra-Judicial Settlement of Estate. Luis claimed to be the surviving spouse of Severina de Asis, with whom he alleged to have acquired several real properties as conjugal partnership assets. He asserted that Severina, without his knowledge or consent, transferred some of these properties to their daughter, Jo-Ann Diaz-Salgado, and that their other daughter, Maria Luisa Anson-Maya, subsequently adjudicated herself as Severina's sole heir for the remaining properties. Luis contended that these actions divested him of his share in the conjugal properties and his inheritance. The Spouses Salgado and Spouses Maya countered that Luis and Severina were merely common-law partners whose relationship was terminated by a Partition Agreement, and that the properties in question were Severina's exclusive acquisitions. Procedural History: The Regional Trial Court (RTC) of Pasig City, Branch 155, initially denied the demurrers to evidence filed by the Spouses Salgado and Spouses Maya. After the Court of Appeals (CA) directed the RTC to resolve the demurrers with specific reasons, the RTC again denied them, finding that Luis had sufficiently established his claims. The RTC subsequently rendered a Decision in favor of Luis, declaring the marriage between Luis and Severina valid and annulling the deeds of sale and settlement. The RTC later issued another Decision annulling the Deed of Extra-Judicial Settlement of Estate. The Spouses Salgado and Spouses Maya appealed to the CA. The CA, after the Spouses Maya entered into a compromise agreement with Luis, dismissed the appeal of the Spouses Salgado, affirming the RTC's decision. The Spouses Salgado then filed the present petition for review on certiorari with the Supreme Court. The Petition: The petitioners, Jo-Ann Diaz-Salgado and her husband Dr. Gerard C. Salgado, seek review of the CA's decision affirming the RTC's ruling. They argue that the marriage between Luis Anson and Severina de Asis is null and void due to the absence of a marriage license, as evidenced by the marriage contract itself, which states no license was exhibited and cites Article 77 of the Civil Code as the reason, implying an exceptional character for the marriage. The petitioners contend that this marriage does not fall under the exceptions provided by law and that Luis failed to prove the existence of a marriage license. They also assert that the Partition Agreement between Luis and Severina is valid and that Luis is estopped from denying its terms, as he received his share and the properties in question were Severina's exclusive acquisitions.
Issue(s)
Whether the Court of Appeals committed reversible error in affirming the RTC decision which declared the marriage between Luis and Severina valid and the subject lands as conjugal properties, considering the absence of a marriage license. Whether the absence of a marriage license can be proven based on the marriage contract itself, especially when it contains a statement that no marriage license was exhibited and claims an exceptional character for the marriage. Whether the Partition Agreement executed by Luis and Severina is valid despite the absence of judicial approval, considering the marriage was void ab initio.
Ruling
The petition is GRANTED. The Decision dated August 6, 2012 and the Resolution dated November 26, 2012 of the Court of Appeals in CA-G.R. CV No. 92989 are REVERSED and SET ASIDE. The Complaint filed in Civil Case No. 69611 is DISMISSED.
Ratio Decidendi
On the validity of the marriage and the absence of a marriage license: The Court held that a marriage license is a requisite for a valid marriage under the Civil Code, and its absence renders the marriage void ab initio, except for marriages of exceptional character. The marriage contract between Luis and Severina explicitly stated that no marriage license was exhibited to the solemnizing officer, citing Article 77 of the Civil Code as the reason. However, Article 77 pertains to the ratification of a civil marriage through a religious ceremony, which requires a prior valid civil marriage. Luis' own testimony confirmed that the December 28, 1966 ceremony was the only marriage ceremony and it was a civil one officiated by the mayor, not a ratification of a prior civil marriage. Therefore, the marriage did not fall under the exceptional character provided by Article 77. The Court found that the marriage contract, being a public document, served as prima facie evidence of the facts stated therein, including the absence of a marriage license and the false claim of exceptional character. Consequently, the burden shifted to Luis to prove that a marriage license was indeed secured, which he failed to do. His reliance on the presumption of validity was insufficient against the prima facie evidence presented by the marriage contract itself. The Court distinguished this case from Geronimo v. CA, where the marriage contract did not claim an exceptional character and a marriage license number was later found. The Court concluded that the marriage between Luis and Severina was celebrated without a valid marriage license and was thus void ab initio. On proving the absence of a marriage license: The Court held that the marriage contract, being a public document, served as prima facie evidence of the facts stated therein, including the absence of a marriage license and the false claim of exceptional character. Consequently, the burden shifted to Luis to prove that a marriage license was indeed secured, which he failed to do. His reliance on the presumption of validity was insufficient against the prima facie evidence presented by the marriage contract itself. On the validity of the Partition Agreement: The Court ruled that the Partition Agreement executed by Luis and Severina in November 1980 is valid. Given that their marriage was declared void ab initio, their property relations during their cohabitation are governed by Article 147 of the Family Code (formerly Article 144 of the Civil Code), which deals with property relations of couples living as husband and wife without the benefit of marriage or under a void marriage. Under this provision, property acquired through their work or industry is owned in equal shares by co-ownership. The law allows partition by agreement between the parties, and judicial approval is not a prerequisite for its validity. Luis admitted the existence, due execution, and authenticity of the Partition Agreement and that he had already received his share as stipulated. Therefore, there was no reason to declare the agreement null and void or annulled.
Main Doctrine
A marriage solemnized without a marriage license is void ab initio, and the absence of a marriage license can be established by the marriage contract itself, especially when it contains a statement that no license was exhibited and falsely claims an exceptional character for the marriage. The burden to prove the existence of the marriage license shifts to the party claiming its validity when such a statement appears on the marriage contract.