A.M. No. MTJ-02-1390 - Aranes vs. Occiano

Petitioner Mercedita Mata Araaes charged respondent Judge Salvador M. Occiano with gross ignorance of the law via sworn complaint dated May 23, 2001.
Respondent was Presiding Judge of the Municipal Trial Court of Balatan, Camarines Sur.

On February 17, 2000, respondent solemnized the marriage of petitioner and her late groom, Dominador B. Orobia, without a valid marriage license.
The marriage ceremony was held in Nabua, Camarines Sur, outside the territorial jurisdiction of respondent judge.
Petitioner and Orobia lived as husband and wife until Orobia's death.
Since the marriage was declared null, petitioner’s right to inherit Orobia’s properties and receive his pensions was denied.
Petitioner prayed for sanctions against the respondent judge for illegal acts and ethical violations causing hardship and embarrassment.

According to his comment dated July 5, 2001, respondent was requested on February 15, 2000, by Juan Arroyo to solemnize the marriage on February 17, 2000.
Believing all documents were complete, he initially agreed to solemnize the marriage at his court in Balatan.
On the wedding day, Arroyo informed respondent that Orobia could not travel due to physical infirmity and requested the ceremony to be held in Nabua. Respondent agreed.
Before starting, respondent discovered the absence of a marriage license and initially refused to proceed, suggesting resetting the wedding.
Due to the parties’ earnest pleas, the presence of guests, and concerns over Orobia’s health, respondent proceeded with the marriage out of human compassion.
He admonished the parties about the necessity of the license and its absence rendering the marriage void. Parties assured issuance of the license later that day but failed to comply.
Respondent denied telling parties the marriage was valid without a license and attributed petitioner’s hardship to her own negligence.

On September 12, 2001, petitioner filed an affidavit of desistance stating respondent initially refused to solemnize due to the absence of a license and that she prodded him to proceed.
She admitted filing the complaint out of rage and expressed remorse after reading respondent’s comment.

Petitioner and Orobia applied for a marriage license on January 5, 2000, with a due issuance date of January 17, 2000, but never claimed it.
Official certifications from the Civil Registrar General and the Local Civil Registrar of Nabua confirmed no record of the marriage existed.
Respondent wrote to the Local Civil Registrar, who replied stating Orobia failed to submit the Death Certificate of his previous spouse, impeding issuance of the license.

The Office found respondent judge guilty of solemnizing a marriage without a duly issued marriage license and outside his territorial jurisdiction.
Recommended a fine of P5,000.00.

The Court referred to prior precedent in Navarro vs. Domagtoy, where solemnizing marriage outside territorial jurisdiction was held to warrant administrative liability and suspension.
The Court emphasized the importance of judges’ proficiency in the law and their responsibility to adhere to the law in solemnizing marriages.

Whether respondent judge committed gross ignorance of the law by solemnizing a marriage without a valid marriage license.
Whether respondent judge committed gross ignorance of the law by solemnizing a marriage outside his territorial jurisdiction.
Whether the withdrawal/desistance of the complaint by petitioner absolves respondent judge from disciplinary liability.