G.R. No. 182438 - Ronulo vs. People

Case Summary (G.R. No. 182438)

Petitioner

Fr. Rene Ronulo, an Aglipayan Church priest charged with performing an illegal marriage ceremony without a valid marriage license.

Respondent

The People of the Philippines.

Key Dates

– March 29, 2003: Alleged wedding ceremony.
– April 3, 2008: Court of Appeals decision.
– July 2, 2014: Supreme Court decision.

Applicable Law

– 1987 Philippine Constitution (Articles 1, 15).
– Family Code of the Philippines (Articles 3[3], 6).
– Revised Penal Code, Article 352 as amended.
– Act No. 3613 (Marriage Law), Sections 39 and 44.

Factual Background

Joey Umadac and Claire Bingayen, without a marriage license, sought Fr. Ragaza in the Sta. Rosa Catholic Parish but were refused. They proceeded to Fr. Ronulo’s Aglipayan Church where he agreed to bless and conduct a ceremony. Witnesses saw ring exchanges, declarations “husband and wife,” and signing of a document; no valid license existed.

MTC Decision

The Municipal Trial Court convicted Fr. Ronulo of Article 352 RPC for solemnizing an illegal ceremony. It treated his blessing as official recognition and imposed a ₱200 fine under Section 44 of the Marriage Law.

RTC Decision

The Regional Trial Court affirmed the MTC, finding the ceremony met statutory minima (personal appearance, declaration before two witnesses) and credited prosecution testimony over the petitioner’s denials. It clarified that Section 39 did not apply and sustained the fine under Section 44.

CA Decision

The Court of Appeals affirmed:

No prescribed form or religious rite is required for solemnization.
The ceremony satisfied appearance and verbal declaration requirements (Family Code Articles 3[3], 6).
Criminal liability under RPC Article 352 is independent of any charge against the couple.
Penalty properly imposed under Section 44 of the Marriage Law.

Petition for Review

Fr. Ronulo contended:

Article 352 is vague and absent clear definition of “illegal marriage ceremony.”
Separation of Church and State precludes treating a blessing as marriage solemnization.
He acted in good faith without criminal intent.
Non-prosecution of the couple bars charges against him.
Section 44 does not cover his act.

Issues Presented

Whether the petitioner’s ecclesiastical blessing constituted an “illegal marriage ceremony” under Article 352 RPC as amended, and whether the penalty under Section 44 of the Marriage Law was proper.

Elements of the Offense

Article 352 RPC penalizes an authorized solemnizing officer who performs an illegal ceremony. The requirements are:

Authority of the solemnizing officer (admitted).
Performance of a marriage ceremony (personal appearance and verbal declaration).

Supreme Court’s Analysis

– Family Code Articles 3(3) and 6, mirroring Civil Code and the Marriage Law, define a marriage ceremony as personal appearance before the officer plus declaration “husband and wife” before two witnesses.
– Testimony of witnesses and petitioner’s admissions established both elements.
– Questions by the trial judge did not vitiate witness credibility; no timely objection was raised.
– Separation of Church and State is respected: no prescribed form is mandated, but minimum requirements apply.
– Constitution (Art. 15) recognizes marriage as an inviolable social institution and permits regulation to protect its sanctity.

Illegality of the Ceremony

The petitioner knew no marriage license exi

Case Syllabus (G.R. No. 182438)

Factual Antecedents

Joey Umadac and Claire Bingayen scheduled to marry on March 29, 2003 at Sta. Rosa Catholic Parish Church, San Nicolas, Ilocos Norte.
Fr. Mario Ragaza refused to solemnize the marriage for lack of a marriage license.
The couple, dressed in wedding attire, proceeded to the Aglipayan Church and asked Fr. Rene Ronulo to officiate.
Petitioner agreed despite being informed there was no marriage certificate; he arranged his choir and scheduled a mass.
Ceremony held before the groom, bride, parents, sponsors, and invited guests; rites included exchange of rings, kiss, signing of an instrument, and blessing.

Charge and Plea

Information filed in the Municipal Trial Court of Batac for violation of Article 352 of the Revised Penal Code, as amended, for performing an illegal marriage ceremony.
Petitioner entered a plea of not guilty at arraignment.

Prosecution Evidence

Joseph Yere and Mary Anne Yere, principal and secondary sponsors, testified to witnessing the bride’s procession, ring exchange, kiss, signing of the marriage document, and hearing petitioner instruct sponsors to sign.
Mary Anne identified the wedding invitation and saw petitioner at the reception.
Florida Umadac (groom’s mother) heard the couple declare “we take each other as husband and wife.”
Municipal Registrar’s certificate confirmed no marriage license was issued to the couple.

Defense

Admitted conducting a blessing but denied it amounted to solemnizing marriage under law.
Argued Article 352 RPC is vague, and a valid ceremony requires verbal declaration plus a written certificate under Civil Code Article 55 and Family Code Article 6.
Claimed separation of church and State prohibits state qualification of an ecclesiastical blessing as a marriage ceremony.
Asserts lack of criminal intent and good-faith moral guidance.
Contended that non-filing of charges against the contracting parties precludes his prosecution.
Maintained Article 352 does not prescribe a penalty and Section 44 of the Marriage Law is inapplicable.

Municipal Trial Court Decision

Found petitioner guilty of violating Article 352 RPC by