Title
Republic vs. Court of Appeals
Case
G.R. No. 103047
Decision Date
Sep 2, 1994
Marriage declared void due to absence of a marriage license, proven by civil registrar's certification; Supreme Court upheld appellate ruling.

Case Digest (G.R. No. 103047)
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)

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