Facts:

The case at hand involves a petition filed by private respondent Angelina M. Castro against Edwin F. Cardenas and the Republic of the Philippines, which was brought before the Regional Trial Court of Quezon City. The petition sought a judicial declaration of nullity of the marriage between Castro and Cardenas, which took place on June 24, 1970, in a civil ceremony officiated by Judge Pablo M. Malvar, a City Court Judge in Pasay City. Castro claimed that no marriage license was issued prior to their marriage. Despite being notified, Cardenas failed to respond to the petition, resulting in his being declared in default, and the trial proceeded without his presence.

The couple's marriage was conducted without the knowledge of Castro's parents, and Cardenas was responsible for processing the necessary documents, including the marriage license. The marriage contract indicated that marriage license no. 3196182 was issued on June 24, 1970, in Pasig, Metro Manila. However,...

Facts:

Marriage and Cohabitation

• On June 24, 1970, Angelina M. Castro and Edwin F. Cardenas were married in a civil ceremony performed by Judge Pablo M. Malvar, City Court Judge of Pasay City. The marriage was conducted without the knowledge of Castro's parents.
• Cardenas personally handled the processing of the required documents, including the procurement of the marriage license. The marriage contract indicated that marriage license no. 3196182 was issued on June 24, 1970, in Pasig, Metro Manila.
• The couple did not live together immediately after the marriage due to the secrecy of the union. They began cohabiting in March 1971 when Castro discovered she was pregnant. However, their cohabitation lasted only four months before they separated.

Discovery of Lack of Marriage License

• On October 19, 1971, Castro gave birth to a child, who was later adopted by Castro's brother with Cardenas' consent. The child is now in the United States.
• In 1987, Castro consulted a lawyer, Atty. Frumencio E. Pulgar, to annul her marriage. Through their investigation, they discovered that no marriage license was issued to Cardenas prior to the marriage.
• A certification from the Civil Register of Pasig, Metro Manila, dated February 20, 1987, confirmed that marriage license no. 3196182 could not be found in their records.

Trial Court Proceedings

• Castro filed a petition for the judicial declaration of nullity of her marriage in the Regional Trial Court of Quezon City. Cardenas failed to file an answer and was declared in default.
• The trial court denied Castro's petition, ruling that the certification from the civil registrar was insufficient to prove the absence of a marriage license. The court held that the inability to locate the license did not conclusively prove its non-issuance.

Appellate Court Decision

• Castro appealed to the Court of Appeals, which reversed the trial court's decision. The appellate court declared the marriage null and void due to the absence of a marriage license and directed the Civil Registrar of Pasig to cancel the marriage contract.

Issue:

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Ruling:

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Ratio:

1. Essential Requisites of Marriage: Under the New Civil Code, a marriage license is an essential requisite for a valid marriage. The absence of a marriage license renders the marriage void ab initio.
2. Proof of Lack of Record: A certification from the custodian of records stating that a diligent search failed to locate a specific document is admissible as evidence under Section 29, Rule 132 of the Rules of Court.
3. Credibility of Testimony: The uncorroborated testimony of a party may be sufficient to establish a claim, especially when the opposing party fails to participate in the proceedings and there is no evidence of collusion.
4. Presumption of Regularity: While there is a presumption that public officers perform their duties regularly, this presumption does not override clear and convincing evidence to the contrary, such as the absence of a marriage license.