Case Digest (G.R. No. 182438)
Facts:
Rene Ronulo v. People of the Philippines, G.R. No. 182438, July 02, 2014, Supreme Court Second Division, Brion, J., writing for the Court.Petitioner Fr. Rene Ronulo (an Aglipayan priest) was criminally charged with performing an illegal marriage ceremony in violation of Article 352 of the Revised Penal Code (RPC), as amended. The respondent is the People of the Philippines. The case arose from events of March 29, 2003 when Joey Umadac and Claire Bingayen were to be married at the Sta. Rosa Catholic Parish Church of San Nicolas, Ilocos Norte, but the Catholic priest refused to solemnize the marriage upon learning the couple had no marriage license.
After the refusal, the couple and their guests proceeded to the Independent Church of Filipino Christians (Aglipayan Church), where petitioner agreed to perform a ceremony despite being informed the couple lacked a marriage license. Petitioner prepared a mass and conducted a ceremony on the same date in the presence of the contracting parties, their parents, sponsors and other guests. Witnesses testified to the couple’s walking down the aisle, exchange of rings, the signing of a document, and the petitioner instructing sponsors to sign the marriage contract; one witness testified she heard the couple declare during the ceremony that they take each other as husband and wife.
An information for violation of Article 352, RPC, as amended, was filed against petitioner before the Municipal Trial Court (MTC) of Batac, Ilocos Norte. Petitioner pleaded not guilty. The MTC found him guilty and imposed a P200 fine under Section 44 of Act No. 3613 (the Marriage Law), reasoning that the petitioner’s blessing amounted to an official church recognition of the cohabitation as husband and wife and that Article 352 (a later law) established the penal standard applied via the Marriage Law. On appeal the Regional Trial Court (RTC), Branch 18, Batac, affirmed the conviction and agreed a marriage ceremony occurred but altered its reasoning regarding the penal provision. The Court of Appeals (CA), in CA‑G.R. CR. No. 31028 (decision dated April 3, 2008, penned by Associate Justice Jose L. Sabio, Jr., with Justices Jose C. Reyes, Jr. and Ramon M. Bato, Jr.), affirmed the RTC: it found the prosecution proved the minimum statutory requirements of a marriage ceremony and that Article 352’s penalty should be imposed pursuant to Section 44 of the Marriage Law.
Petitioner filed a petition for review on certiorari with the Supreme Court (Rule 45), challenging the CA ruling on grounds that Article 352 is vag...(Pro-only)
Issues:
- Were the elements of the offense under Article 352, RPC, as amended, proven—i.e., did petitioner, an authorized solemnizing officer, perform an illegal marriage ceremony?
- Does the principle of separation of church and State prevent a civil court from qualifying a religious blessing as a marriage ceremony for purposes of Article 352?
- Does petitioner’s claimed good faith and lack of criminal intent negate criminal liability for performing the ceremony despite absence of a marriage license?
- Does the non‑filing of charges against the contracting parties under Article 350, RPC, preclude prosecution of the solemnizing officer under Article 352?
- What is the proper penal provision to be applied for a violation of ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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