G.R. No. 211845 - Pen Development Corp. vs. Martinez Leyba, Inc.

Joey Umadac and Claire Bingayen scheduled to marry on March 29, 2003 at Sta. Rosa Catholic Parish Church in San Nicolas, Ilocos Norte.
Catholic priest Fr. Mario Ragaza refused to solemnize the marriage due to absence of a civil marriage license.

The couple, dressed in wedding attire with sponsors and guests, proceeded to the Independent Church of Filipino Christians (Aglipayan Church).
Petitioner Fr. Rene Ronulo, an Aglipayan priest, agreed to conduct a ceremony despite being informed that no marriage license had been secured.
He prepared his choir, held a mass, and officiated the ceremony in the presence of the bride, groom, sponsors, and other guests.
Witnesses Joseph and Mary Anne Yere (veil and cord sponsors) testified they saw the personal appearance of the parties, exchange of rings, kiss, signing of documents, and heard declarations by the couple.
Florida Umadac, the groom’s mother, testified that she heard Joey and Claire declare they take each other as husband and wife.
After the ceremony, family members discovered from the local civil registrar that no marriage license had been issued.

An information was filed in the Municipal Trial Court (MTC) of Batac for violation of Article 352, Revised Penal Code (RPC), as amended (performing an illegal marriage ceremony).
The petitioner pleaded not guilty and denied that his blessing constituted a “solemnization” under the law.
The MTC convicted him and imposed a ₱200 fine under Section 44 of Act No. 3613 (Marriage Law).
The Regional Trial Court (RTC) affirmed the conviction, finding that a marriage ceremony occurred and that Section 39 of Act 3613 was not the proper penal clause.
The Court of Appeals (CA) in CA-G.R. CR. No. 31028 affirmed the RTC decision on April 3, 2008, applying Section 44 of Act 3613 and rejecting petitioner’s defenses.
Petitioner filed a petition for review on certiorari before the Supreme Court.

Whether Fr. Ronulo’s act of blessing the couple, despite knowing there was no marriage license, constitutes the “performance of an illegal marriage ceremony” under Article 352, RPC, as amended.
Whether Article 352 of the RPC is unconstitutionally vague for not defining “illegal marriage ceremony” and whether the minimum requirements of a marriage ceremony include both verbal declaration and a written certificate.
Whether the principle of separation of Church and State precludes the State from converting an ecclesiastical “blessing” into a civil “solemnization.”
Whether petitioner lacked criminal intent (good faith) and whether non-prosecution of the couple under Article 350, RPC, bars the prosecution of the solemnizing officer.
Whether the penalty should be imposed under Section 39 (illegal solemnization) or Section 44 (general penal clause) of Act No. 3613.