G.R. No. L-37945 - People vs. Canete

On May 19, 1969, petitioner Jaime O. Sevilla and respondent Carmelita N. Cardenas purportedly executed a civil marriage contract before Rev. Cirilo D. Gonzales at Manila City Hall, indicating Marriage License No. 2770792 allegedly issued by the Local Civil Registry of San Juan, Rizal.
On May 31, 1969, the couple underwent a religious wedding ceremony before Monsignor Juan Velasco at the Most Holy Redeemer Parish in Quezon City, again reciting License No. 2770792.

The spouses cohabited, had two sons (born March 1970 and later), and lived intermittently in Spain, supported partly by both families; marital difficulties led to separation in 1978.
Petitioner obtained a U.S. divorce decree in 1981 and judicial separation of conjugal partnership in 1983. In 1994, he filed a petition in the Makati RTC to declare his Philippine marriage null for lack of a valid license.
Upon inquiry, the San Juan Civil Registrar issued certifications (March 11, 1994; September 20, 1994; July 25, 2000) stating no record of License No. 2770792, while the church issued a certificate confirming the religious rite and referring to the same fictitious license.

The RTC (Jan. 25, 2002) declared both civil and religious marriages null and void ab initio for absence of a valid license, relying on the registrar’s certificates under Section 28, Rule 132, Rules of Court.
On appeal, the Court of Appeals (Dec. 20, 2004) reversed, finding the presumption of regularity of official acts unrebutted due to failure of the registrar’s office to exert diligent search and produce the logbook, thus preserving the validity of the marriage.

Was there a valid marriage license issued to the parties prior to their civil and religious ceremonies?
Did the Court of Appeals correctly apply the presumption of regularity of official acts in sustaining the marriage license’s validity despite certifications of non-issuance?
Could respondent validly invoke the presumption of validity of marriage arising from the parties’ long cohabitation and public conduct as husband and wife?