Case Digest (G.R. No. 196735) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Rosario D. Ado-an-Morimoto v. Yoshio Morimoto and the Republic of the Philippines, petitioner Rosario D. Ado-an-Morimoto alleges that her purported marriage to respondent Yoshio Morimoto on December 5, 2007 at Manila City Hall was wholly simulated to facilitate her acquisition of a Japanese visa. She and Yoshio signed a blank marriage certificate under assurance it would not be recorded. Months later, she discovered through the Philippine Statistics Authority that a marriage certificate bearing Marriage License No. 6120159, supposedly issued by San Juan City, was registered under their names. On October 5, 2009, Rosario filed a Petition for Declaration of Nullity of Marriage before the Quezon City Regional Trial Court (RTC), contending there was no bona fide ceremony or license. The Assistant City Prosecutor reported no collusion between the parties. During trial, Rosario introduced (1) the registered Certificate of Marriage, (2) a June 17, 2008 Certification by the National Case Digest (G.R. No. 196735) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and simulated marriage arrangement
- Petitioner Rosario D. Ado-an-Morimoto, seeking a Japanese visa, was introduced by a friend to respondent Yoshio Morimoto as a candidate for a simulated marriage.
- On December 5, 2007, at Manila City Hall, Rosario and Yoshio signed a blank marriage certificate under assurance from the solemnizing officer that it would never be registered or recorded.
- Discovery of registered marriage
- When Rosario later secured a Certificate of No Marriage from the Philippine Statistics Authority (PSA), she was surprised to find a registered Certificate of Marriage showing a ceremony in San Juan City on December 5, 2007, officiated by “Reverend Roberto Espiritu” and based on Marriage License No. 6120159.
- Rosario testified that no wedding ceremony took place and that Yoshio never engaged in any marital relations with her.
- Proceedings below
- October 5, 2009: Rosario filed a Petition for Declaration of Nullity of Marriage in the Quezon City RTC (Civil Case No. Q-09-65737), claiming absence of ceremony and license.
- Evidence presented:
- The allegedly genuine Certificate of Marriage.
- June 17, 2008 NSO Certification stating that the PSA mistakenly certified a solemnization.
- June 4, 2009 San Juan Registrar Certification that no record of Marriage License No. 6120159 existed.
- Testimony of Mary Ann C. Chico, Registration Officer III, authenticating the June 4, 2009 Certification.
- September 21, 2011: Assistant City Prosecutor’s Report finding no collusion between the parties.
- January 7, 2016: RTC Decision (Judge Jose L. Bautista, Jr.) denied the petition; motion for reconsideration likewise denied.
- October 10, 2018: Court of Appeals Decision (CA-G.R. CV No. 108043) denied Rosario’s appeal.
- April 25, 2019: Court of Appeals Resolution denied motion for reconsideration.
- Rosario elevated the case to the Supreme Court via a Petition for Review on Certiorari under Rule 45.
Issues:
- Whether the registered marriage between Rosario and Yoshio is void ab initio for lack of genuine consent and absence of a valid marriage ceremony.
- Whether the registered marriage is void ab initio for failure to secure the required marriage license under the Family Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)