CASE DIGEST NO.

25

G.R. No. 103047

September 2, 1994
REPUBLIC OF THE PHILIPPINES, petitioner,
vs
COURT OF APPEALS, PEDRO PILAPIL and ANGELINA M. CASTRO, respondents.

FACTS OF THE CASE:

Angelina M. Castro and Edwin F. Cardenas were married in a civil ceremony in the City Court of Pasay
City. The marriage was celebrated without the knowledge of Castro’s parents. The couple did not
immediately live together as husband and wife since the marriage was unknown to Castro’s parents.
When Castro discovered she was pregnant, the couple decided to live together. However, their
cohabitation lasted only for four (4) months. Thereafter, the couple parted ways. After giving birth,
Castro’s baby was adopted by her brother with the consent of Cardenas. Desiring to follow her daughter
in the United States, Castro wanted to put in order her marital status. Thus, she consulted a lawyer
regarding the possible annulment of her marriage. Through her lawyer’s effort, they discovered that
there were no marriage licensed issued to Cardenas prior to the celebration of their marriage. Castro
filed a petition in the RTC of Quezon City seeking a judicial declaration of nullity of her marriage to Edwin
Cardenas. The RTC denied respondent petition, unsatisfied with the decision, Castro appealed to
appellate court which reversed the decision of the trial court. Hence, this petition for review on
certiorari.
ISSUE:
1. Whether or not the documentary and testimonial evidence presented by private respondent are
sufficient to establish that no marriage license was issued by the Civil Registrar of Pasig prior to
the celebration of the marriage of private respondent to Edwin F. Cardenas; and
2. Whether or not the marriage is valid.
RULING:
Yes, the court ruled that the certification issued by the Civil Registrar unaccompanied by any
circumstance of suspicion and pursuant to Section 29, Rule 132 of the Rules of Court, sufficiently proved
that the Civil Registrar did not issue marriage license to the contracting parties. Although, the fact that
Castro’s testimony was not supported by any other witnesses, it is not a bar to deny her petition
because of the peculiar circumstances of her case. Furthermore, Cardenas was duly informed of the
proceedings but he failed to participate.
At the time of the marriage, the law governing marital relations was the New Civil Code. The law
provides that no marriage shall be solemnized without a marriage license first issued by the local civil
registrar. Being one of the requisites of a valid marriage, absence of a license would render the marriage
void ab initio.

Eric M. Recomendable
Arellano University School of Law