G.R. No. 103047 - Republic vs. Court of Appeals

The case originated from a petition filed by Angelina M. Castro in the Regional Trial Court of Quezon City.
Castro sought a judicial declaration of nullity of her marriage to Edwin F. Cardenas, claiming that no marriage license was issued prior to their marriage.
Cardenas failed to file an answer to the petition and was declared in default, leading to a trial in his absence.

Angelina M. Castro and Edwin F. Cardenas were married on June 24, 1970, in a civil ceremony conducted by Judge Pablo M. Malvar in Pasay City.
The marriage was conducted without the knowledge of Castro's parents, and Cardenas managed the documentation, including the marriage license.
The marriage contract indicated that marriage license no. 3196182 was issued on June 24, 1970, in Pasig, Metro Manila.
The couple did not cohabit immediately due to the secrecy of the marriage, only living together for four months after Castro became pregnant.
Castro gave birth on October 19, 1971, and the child was adopted by her brother with Cardenas's consent.

Castro sought legal advice to annul her marriage before relocating to the United States to be with her daughter.
Through her lawyer, it was discovered that no marriage license had been issued to Cardenas prior to their marriage.
A certification from the Civil Register of Pasig confirmed the non-existence of marriage license no. 3196182.

The trial court denied Castro's petition, stating that the certification was insufficient to prove the non-issuance of a marriage license.
The court ruled that the inability of the civil registrar to locate the marriage license did not conclusively demonstrate that it was never issued.

Dissatisfied with the trial court's decision, Castro appealed to the appellate court, which reversed the trial court's ruling.
The appellate court declared the marriage null and void and ordered the cancellation of the marriage contract by the Civil Registrar of Pasig.

The Republic of the Philippines filed a petition for review, arguing that the appellate court erred in relying on the civil registrar's certification and Castro's uncorroborated testimony.
The petitioner contended that the presumption of validity of the marriage should prevail, given that the solemnizing officer attested to the presentation of the marriage license.

The central issue was whether the evidence presented by Castro was sufficient to establish that no marriage license was issued prior to the marriage.
The law in effect at the time required a marriage license as an essential requisite for a valid marriage, and its absence rendered the marriage void ab initio.

The Supreme Court affirmed the appellate court's decision, stating that the certification from the civil registrar was adequate proof of the non-issuance of the marriage license.
The certification, as per Section 29, Rule 132 of the Rules of Court, is admissible as evidence of the lack of...continue reading