Republic vs. Court of Appeals

Facts:

Private respondent Angelina M. Castro filed Civil Case No. Q-50117 in the Regional Trial Court (Quezon City) on February 19, 1987, seeking a judicial declaration of nullity of her marriage to Edwin F. Cardenas on the ground that no marriage license had been issued prior to the solemnization. The marriage had been celebrated on June 24, 1970 in a civil ceremony before Judge Pablo M. Malvar, City Court Judge of Pasay City. The marriage contract recited that marriage license No. 3196182 was issued in Pasig on June 24, 1970. Defendant Cardenas was served but did not answer and was declared in default; trial proceeded in his absence.

Castro testified she never applied for or signed for a marriage license in Pasig and only appended her signature to the marriage contract on June 24, 1970. After discovering she was pregnant in March 1971 the couple cohabited briefly; their child was born October 19, 1971 and later adopted by Castro’s brother; the child is now in the United States. When Castro consulted counsel years later to regularize her status before leaving for the United States, counsel procured from the Civil Registrar of Pasig a certification, dated February 20, 1987, stating that marriage license No. 3196182 “does not appear from our records.”

The trial court (Quezon City RTC, Branch LXXXVI) denied Castro’s petition in a decision dated June 30, 1987, holding that the civil registrar’s inability to locate the license was not conclusive proof that it had not been issued. The Court of Appeals (Sixteenth Division) reversed in a decision dated November 27, 1991 (penned by Justice Justo P. Torres, with Justices Ricardo J. Francisco and Consuelo Ynares‑Santiago concurring), declaring the marriage null and void and directing cancellation of the marriage contract. The Republic of the Philippines (as petitioner) sought review in this Court by a petition for review on certiorari, challenging (a) the ...(Pro-only)

Issues:

• Is the certification of the Civil Registrar of Pasig, stating that marriage license No. 3196182 does not appear in the records after diligent search, sufficient to prove that no marriage license was issued prior to the marriage?
• Can private respondent Castro’s uncorroborated testimony, in the circumstances of this case, suffice to establish the non‑issuance of the marriage...(Pro-only)

Ruling:

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Ratio:

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Doctrine:

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