G.R. No. 4904 - Martinez vs. Tan

An expediente de matrimonio civil was received in evidence, consisting of several interconnected documents all dated September 25, 1907.
The expediente included:

A petition signed by both the plaintiff and the defendant, asserting their mutual agreement to contract marriage before the justice of the peace.
A document issued on the same day and signed by the justice of the peace, both contracting parties, and the two witnesses (Zacarias Esmero and Pacita Ballori). This document records the presentation of the petition, the physical presence of the parties and witnesses, and their ratification under oath.
A certificate of marriage signed by the justice of the peace and the witnesses, which formally stated that a legal marriage had been solemnized that day.

The defendant testified that both he and the plaintiff appeared before the justice of the peace at the designated time along with the witnesses, thereby confirming the occurrence of the ceremony.
Zacarias Esmero corroborated that the plaintiff, the defendant, and witness Pacita Ballori were present and had signed the pertinent documents.
Pacita Ballori testified as to her direct observations:

Stated that around 5 o’clock in the afternoon, at the request of the defendant, she went to a Chinese store (owned by Veles) where she encountered the plaintiff and her mother.
Agreed that after leaving the store under the pretext of examining dress patterns (upon the mother’s consent), the plaintiff instead proceeded directly to the justice of the peace’s office where the marriage was solemnized.

Jose Santiago, the bailiff for the court of the justice of the peace, attested to the presence of all the key participants in the office at the time of the ceremony.

The plaintiff testified that she never appeared before the justice of the peace nor was married to the defendant.
She admitted having signed the document but claimed that:

The signing occurred at her home, not in the presence of the justice of the peace.
The signature was executed at the defendant’s request under the misapprehension that it was a document to secure parental consent for marriage.

The plaintiff also presented some indirect evidence, including testimony by Rosario Bayot (the wife of her married brother), which suggested she was confined mostly to the household, although this was undermined by cross-examination and Pacita Ballori’s more persuasive account.

A series of letters purportedly written by the plaintiff (with several of undisputed authenticity) furnished additional evidence regarding the events surrounding the marriage:

Letter No. 9 indicated the plaintiff’s fear of her father’s discontent if it was known that a civil marriage had occurred.
Letter No. 6, dated to the morning of the 25th, arranged a meeting in the afternoon for the signing with explicit instructions involving the presence of witness Pacita Ballori.
Letters No. 7 and No. 8, written after the marriage ceremony, further corroborated post-ceremony communications concerning the marital arrangement and subsequent actions.

These letters, together with the extant testimony of witnesses, strongly bolstered the evidence that the marriage had indeed taken place before the justice of the peace.

The defendant’s original answer was a general denial of the complaint’s allegations, including the claim of marriage under conditions contingent on parental consent.
The defendant was later permitted to amend his answer:

A first amendment modifying his denial regarding the parental consent condition was followed by a second amendment.
The second amendment, which effectively reversed the first, clarified and consolidated his position regarding the marriage, and was allowed by the court without prejudice to the defendant.

The proceedings continued without the plaintiff requesting a continuance, and all parties proceeded to trial based on the evidence presented.

Whether the acts and formalities performed on September 25, 1907—comprising the petition, the signing of the document and certificate, and the subsequent declarations—constituted a legally valid marriage in accordance with the law.
Whether the direct and corroborative documentary and testimonial evidence outweighed the plaintiff’s contradictory claims of non-appearance before the justice of the peace.

Whether the cumulative probative evidence—ranging from witness testimony (including that of Zacarias Esmero and Pacita Ballori) to the authentic letters—adequately supported the finding that the plaintiff and the defendant were married before the solemnizing officer.
Whether the allowance of the defendant’s amendments to his answer affected or prejudiced the determination of the case.

Whether the simple formality of declaring mutual consent before a justice of the peace (as prescribed by General Orders No. 68, Section 6) sufficed to establish a legal marriage, despite any alleged irregularities in the plaintiff’s account.