Sevilla vs. Cardenas

Facts:

Petitioner Jaime O. Sevilla filed a complaint on March 28, 1994 in the Regional Trial Court (RTC) of Makati, Civil Case No. 94‑1285, seeking declaration that his marriage to respondent Carmelita N. Cardenas was void ab initio for lack of a marriage license. Petitioner alleged that on May 19, 1969 he and respondent were purportedly married before a Reverend Cirilo D. Gonzales at Manila City Hall but never applied for or obtained any marriage license; a marriage license number (No. 2770792) shown on the marriage contracts was alleged to be fictitious. The parties also had a religious ceremony on May 31, 1969 at the Most Holy Redeemer Parish which used the same license number.

At trial both parties testified and presented documentary evidence. Petitioner produced certifications from the Local Civil Registrar of San Juan (dated March 4 and March 11, 1994; September 20, 1994; and a later certification of July 25, 2000) stating that no Marriage License No. 2770792 was issued and that no application was filed; the registrar’s office also testified that it failed to locate the logbook where the entry might have been recorded, explaining the person who handled it had retired. Respondent testified to the civil and religious ceremonies, long cohabitation, and family life, and denied petitioner’s claim that no license was issued.

The RTC (Judge Zeus C. Abrogar) rendered judgment on January 25, 2002 declaring the civil and church marriages null and void for lack of the requisite marriage license and ordered cancellation of the marriage record in the Local Civil Registry of Manila. Respondent appealed to the Court of Appeals (docketed CA‑G.R. CV No. 74416). In a Decision dated December 20, 2004 (penned by Associate Justice Vicente S. E. Veloso, with Justices Roberto A. Barrios and Amelita G. Tolentino concurring), the Court of Appeals reversed the RTC, holding that the presumption of regularity of official acts and the strong presumption in favor of the validity of marriage had not been overcome given the circumstances surrounding the registrar’s inability to produc...(Pro-only)

Issues:

• Was a valid marriage license issued to the parties prior to the celebration of the marriages in question?
• Did the Court of Appeals correctly apply the presumption of regularity of official acts in assessing the certifications and other evidence concerning the alleged marriage license?
• Could respondent validly invoke the presumption of validity of marriage arising from the parties’ demonstrated fact...(Pro-only)

Ruling:

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Ratio:

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Doctrine:

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