Primary Holding

The Supreme Court denied the petition, affirming the Court of Appeals' decision that the marriage between Jaime O. Sevilla and Carmelita N. Cardenas was valid, as the certifications from the Local Civil Registrar did not conclusively prove the absence of a marriage license.

Background

Jaime O. Sevilla and Carmelita N. Cardenas were married in civil rites on May 19, 1969, and in a church ceremony on May 31, 1969. Jaime later filed a complaint for the nullity of their marriage, claiming that no marriage license was issued for their union. The Regional Trial Court (RTC) declared the marriage null and void, but the Court of Appeals reversed this decision, leading to the present petition.

Facts

• 1. Jaime and Carmelita were married in civil rites on May 19, 1969, and in a church ceremony on May 31, 1969.
• 2. Jaime claimed that no marriage license was issued for their marriage, and the marriage license number on their marriage contract was fictitious.
• 3. Carmelita argued that they were validly married and that Jaime was estopped from questioning the marriage after 25 years.
• 4. The RTC declared the marriage null and void based on certifications from the Local Civil Registrar of San Juan stating that no marriage license was issued.
• 5. The Court of Appeals reversed the RTC decision, holding that the certifications were insufficient to prove the non-issuance of the marriage license.

Arguments of the Petitioners

• 1. Jaime argued that the marriage was void due to the absence of a valid marriage license.
• 2. He relied on certifications from the Local Civil Registrar of San Juan stating that no marriage license was issued.

Arguments of the Respondents

• 1. Carmelita argued that the marriage was valid and that Jaime was estopped from questioning it after 25 years.
• 2. She contended that the certifications from the Local Civil Registrar were inconclusive and did not prove the non-issuance of the marriage license.

Issues

• 1. Whether a valid marriage license was issued for the marriage between Jaime and Carmelita.
• 2. Whether the Court of Appeals correctly applied the presumption of regularity of official acts.
• 3. Whether Carmelita could validly invoke the presumption of validity of the marriage.

Ruling

• 1. The Supreme Court ruled that the certifications from the Local Civil Registrar were insufficient to prove the non-issuance of the marriage license.
• 2. The Court emphasized the presumption of regularity of official acts and the presumption of validity of marriage.
• 3. The Court held that the absence of the logbook where the marriage license was recorded did not conclusively prove the non-issuance of the license.
• 4. The Court affirmed the Court of Appeals' decision, declaring the marriage valid.

Doctrines

• 1. Presumption of Regularity of Official Acts: Official acts are presumed to have been performed regularly unless proven otherwise.
• 2. Presumption of Validity of Marriage: Every intendment of the law leans toward the validity of marriage.

Key Excerpts

• 1. "Every intendment of the law leans toward legalizing matrimony."
• 2. "The presumption of regularity of official acts may be rebutted by affirmative evidence of irregularity or failure to perform a duty."

Precedents Cited

• 1. Carifio v. Carifio: Held that a certification from the Local Civil Registrar is adequate to prove the non-issuance of a marriage license.
• 2. Republic v. Court of Appeals: Emphasized that the certification must categorically state that the document does not exist after a diligent search.

Statutory and Constitutional Provisions

• 1. Article 53 of the Civil Code: Lists the requisites for a valid marriage, including a marriage license.
• 2. Article 58 of the Civil Code: Requires a marriage license for the solemnization of marriage, except in exceptional cases.
• 3. Article 80 of the Civil Code: Declares marriages solemnized without a marriage license void, except in exceptional cases.
• 4. Section 28, Rule 132 of the Rules of Court: Provides that a certification from the custodian of documents stating that a document does not exist after a diligent search is admissible as evidence.