Case Digest (G.R. No. 103047) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Republic of the Philippines vs. Court of Appeals and Angelina M. Castro (G.R. No. 103047, September 2, 1994), private respondent Angelina M. Castro filed on February 19, 1987 before the Regional Trial Court of Quezon City, Branch LXXXVI, a petition for judicial declaration of nullity of her marriage to Edwin F. Cardenas on the ground that no marriage license was ever issued prior to their civil ceremony solemnized by Judge Pablo M. Malvar in Pasay City on June 24, 1970. Cardenas defaulted for failing to answer, and trial proceeded in his absence. The couple did not live together until Castro’s pregnancy in March 1971; they cohabited only four months before separating. Their daughter, born October 19, 1971, was adopted by Castro’s brother and later moved to the United States. While preparing to follow her child abroad, Castro’s counsel secured on February 20, 1987 a certification from the Civil Registrar of Pasig confirming that marriage license no. 3196182 cannot be found in ... Case Digest (G.R. No. 103047) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Background
- Private respondent Angelina M. Castro filed in the Regional Trial Court of Quezon City a petition for judicial declaration of nullity of her marriage to Edwin F. Cardenas on the ground that no marriage license was ever issued.
- Edwin F. Cardenas failed to answer despite notice, was declared in default, and trial proceeded in his absence.
- Key Factual Events
- On June 24, 1970, Castro and Cardenas were married in a civil ceremony by Judge Pablo M. Malvar in Pasay City. The marriage contract recited that marriage license no. 3196182 was issued on the same date in Pasig.
- The couple kept the marriage secret from Castro’s parents and did not immediately cohabit. In March 1971, upon discovering her pregnancy, they lived together for four months before separating.
- On October 19, 1971, Castro gave birth; the child was adopted by Castro’s brother with Cardenas’s consent and later went to the United States.
- In February 1987, Castro obtained from the Civil Registrar of Pasig a certification that after diligent search, no record of marriage license no. 3196182 could be found.
- The trial court denied the nullity petition; the Court of Appeals reversed, declared the marriage void, and ordered cancellation of the contract; the Republic of the Philippines then filed this petition for review.
Issues:
- Whether the certification of due search and inability to locate marriage license no. 3196182 is admissible and sufficient proof of non-issuance.
- Whether private respondent’s uncorroborated testimony, in view of the secret nature of the marriage, suffices to establish absence of a license.
- Whether the presumption of regularity in the solemnizing officer’s attestation in the marriage contract remains irrebuttable.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)