A.M. No. MTJ-02-1390 - Aranes vs. Occiano

Case Summary (A.M. No. MTJ-02-1390)

Factual Background

Petitioner and Orobia executed an Application for Marriage License on 5 January 2000 with a stamp indicating issuance on 17 January 2000, but the license was never claimed. On 17 February 2000 respondent judge solemnized their marriage in Nabua. After Orobia’s death, petitioner’s status as spouse was not recognized for purposes of inheritance and pension, and the civil registries of the Philippines (Office of the Civil Registrar General and Local Civil Registrar of Nabua) had no record of the alleged marriage.

Petitioner’s Allegations and Relief Sought

By sworn letter‑complaint dated 23 May 2001 petitioner charged respondent judge with gross ignorance of the law for solemnizing a marriage without a duly issued marriage license and outside his territorial jurisdiction. She attributed substantial hardship, embarrassment, and a loss of benefits (inheritance and pension) to respondent’s actions, and prayed for sanctions to be imposed.

Respondent’s Explanation (Comment)

In his Comment (5 July 2001) respondent stated that he was requested to solemnize the marriage and had examined the parties’ documents. He reported that, upon discovering the absence of a marriage license, he initially refused to proceed and suggested rescheduling. He acceded, however, to repeat pleas and proceeded to solemnize the marriage at Nabua on humanitarian grounds and because of concern for Orobia’s health (recent stroke and inability to travel). He alleged he warned the parties that failure to produce the license would render the marriage void and that they promised to deliver the license later that day — a promise that was not fulfilled. He denied representing the marriage as valid despite lack of license.

Subsequent Events and Petitioner’s Affidavit of Desistance

Petitioner later filed an Affidavit of Desistance dated 28 August 2001 (submitted 12 September 2001) stating she had prodded the judge to proceed and acknowledging that she filed the administrative complaint initially out of rage. She indicated remorse and expressed that she realized her shortcomings after reading respondent’s Comment.

Documentary and Registry Evidence

The Office of the Civil Registrar General certified it had no record of a marriage on 17 February 2000. The Local Civil Registrar of Nabua likewise certified (7 May 2001) it could not produce a marriage contract as no record existed. A clerk of the Local Civil Registrar (Grace T. Escobal) informed respondent (by letter dated 9 May 2001) that the local office could not issue the marriage license because Orobia had failed to submit the death certificate of his prior spouse.

Procedural Posture and Administrative Handling

The complaint was referred by the Office of the Chief Justice to the Acting Court Administrator for action (28 May 2001). The Office of the Court Administrator required respondent’s comment, obtained it, and later submitted a Report and Recommendation (15 November 2000) finding respondent guilty of solemnizing a marriage without a duly issued license and outside his territorial jurisdiction and recommending a fine of P5,000.00.

Legal Issues Presented

Whether a judge authorized to solemnize marriages may lawfully do so outside his territorial jurisdiction.
Whether solemnization of a marriage in the absence of a duly issued marriage license renders the officiating judge administratively liable (and whether such act constitutes gross ignorance of the law).
Whether the petitioner’s affidavit of desistance should exonerate the judge from disciplinary action.

Analysis — Territorial Jurisdiction

Under B.P. 129 and the Court’s precedents, judges appointed to specific territorial jurisdictions may officiate marriages only within those areas. The Supreme Court’s precedents (Navarro v. Domagtoy) underscore that magistrates whose authority is territorially limited may not validly exercise the function of solemnizing marriages outside their prescribed area; while such an act does not necessarily affect the validity of the marriage itself, it constitutes an administrative irregularity that may attract liability. Respondent’s act of solemnizing the marriage in Nabua — outside his jurisdiction confined to Balatan — contravened this rule and incurs administrative culpability.

Analysis — Requirement of Marriage License

The Court reaffirmed that a marriage solemnized before issuance of the marriage license is void (People v. Lara); the marriage license is a prerequisite that confers authority on the solemnizing officer except in statutorily provided exceptions. Respondent did not possess a valid marriage license when he solemnized the marriage; hence he lacked the requisite authority. The Court held that this omission amounted to gross ignorance of the law insofar as the judge proceeded to solemnize without the mandatory license.

Effect of Petitioner’s Affidavit of Desistance

The Court reiterated established doctrine that the withdrawal of a private complaint does not necessarily preclude disciplinary action. Administrative discipline concerns the institutional integrity of the judiciary and the Court’s constitutional power to discipline judges; it cannot be made to depend solely on a complainant’s unilateral withdrawal. Therefore, petitioner’s affidavit of desistance did not exonerate resp

Case Syllabus (A.M. No. MTJ-02-1390)

Facts of the Case

Petitioner Mercedita Mata Araaes filed a sworn Letter-Complaint dated 23 May 2001 charging respondent Judge Salvador M. Occiano with gross ignorance of the law.
Respondent was the Presiding Judge of the Municipal Trial Court of Balatan, Camarines Sur at the time of the events.
Petitioner alleges that on 17 February 2000 respondent solemnized her marriage to Dominador B. Orobia without a duly issued marriage license and that the ceremony took place in Nabua, Camarines Sur, which lies outside respondent’s territorial jurisdiction (the municipality of Balatan).
Petitioner and Orobia lived as husband and wife following the ceremony until Orobia’s death; petitioner claims her right to inherit Orobia’s properties was not recognized because the marriage was a nullity.
Petitioner also alleges deprivation of pension benefits of Orobia, described in the record as a retired Commodore of the Philippine Navy.
Petitioner prayed for sanctions against respondent for his alleged illegal acts and unethical misrepresentations, asserting that these acts caused her hardship, embarrassment, and suffering.

Procedural History

The Office of the Chief Justice referred the case to then Acting Court Administrator Zenaida N. Elepaño on 28 May 2001 for appropriate action.
On 8 June 2001, the Office of the Court Administrator required respondent to comment on the complaint.
Respondent filed a Comment dated 5 July 2001.
Petitioner later filed an Affidavit of Desistance dated 28 August 2001, which was received by the Office of the Court Administrator on 12 September 2001.
The Office of the Court Administrator issued a Report and Recommendation dated 15 November 2000 finding respondent guilty of solemnizing a marriage without a duly issued marriage license and for doing so outside his territorial jurisdiction, and recommended a fine of P5,000.00.
The Supreme Court, First Division, rendered a decision adopting the OCA recommendation and imposing the penalty described below.

Respondent’s Explanation and Account of Events

Respondent avers that on 15 February 2000 he was requested by a certain Juan Arroyo to solemnize the parties’ marriage on 17 February 2000.
Respondent states he agreed to solemnize the marriage in his sala at the Municipal Trial Court of Balatan after being assured that all documents were complete.
On 17 February 2000, respondent was informed by Arroyo that Orobia had difficulty walking and could not travel to Balatan (approximately 25 kilometers from Orobia’s residence in Nabua), and Arroyo requested that the ceremony be performed in Nabua; respondent acceded to this request.
Respondent asserts that before commencing the ceremony he carefully examined the documents submitted by petitioner and discovered that no marriage license had been presented; he initially refused to solemnize and suggested resetting the ceremony.
Due to the parties’ earnest pleas, the influx of visitors, the delivery of provisions for the occasion, and respondent’s compassion and concern that postponement might aggravate Orobia’s medical condition (recent stroke), respondent proceeded to solemnize the marriage.
After solemnization respondent reiterated the necessity of a marriage license and admonished the parties that lack of a license would render the marriage void; petitioner and Orobia allegedly assured him they would deliver the license that afternoon.
When the license was not delivered, respondent followed up with Arroyo who again reassured him that the license would be delivered to the respondent’s sala in Balatan.
Respondent vigorously denies having told the parties that their marriage was valid despite the absence of a marriage license and attributes petitioner’s alleged hardships to her own fault and negligence.

Petitioner’s Affidavit of Desistance and Statements

Petitioner filed an Affidavit of Desistance dated 28 August 2001 and filed with the OCA on 12 September 2001.
In that affidavit petitioner attested that respondent initially refused to solemnize the marriage due to lack of a duly issu