SC upholds marriage despite doubts on officiant’s authority
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The validity of a marriage was upheld by the Supreme Court (SC) despite questions over the authority of the person who officiated it, ruling that a wedding remains valid if one or both spouses honestly believed that the officiant was legally authorized to solemnize their union.
In a decision penned by retired Associate Justice Mario V. Lopez dated 23 April 2025, the SC’s Second Division dismissed a petition filed by a wife seeking to have her marriage declared void, claiming that the person who officiated their wedding was not the judge named in their marriage certificate.
Records showed the couple was married at the Tarlac City Municipal Hall, with their marriage contract identifying Judge Conrado De Gracia as the solemnizing officer. However, more than two decades later, the wife’s lawyer alleged that the man in their wedding photos was actually Rosalio Florendo, a member of the Tarlac City Rotary Club, and not Judge De Gracia.
With this, the wife filed a petition before the Regional Trial Court (RTC) of Tarlac to nullify the marriage, citing lack of authority of the officiant.
The petition was denied by the RTC, finding insufficient evidence to establish that Florendo, and not Judge De Gracia, had officiated the ceremony.
The high court also noted that the wife herself admitted she believed at the time that it was Judge De Gracia who performed the wedding.
The RTC ruling was later affirmed by the Court of Appeals, stressing that a marriage contract is a public document that serves as prima facie proof of the marriage and its details, including the authority of the officiant.
The appellate court said the wife failed to present clear and convincing evidence to rebut this presumption.
Both lower courts’ decisions were upheld by the SC, citing Articles 3 and 4 of the Family Code, which require that a marriage be officiated by someone with legal authority, and Article 35(2), which provides an exception if one or both parties believed in good faith that the officiant had such authority.
It ruled that the wife failed to prove otherwise, noting that the marriage certificate showed Judge De Gracia was an incumbent judge in Tarlac City at the time and therefore legally empowered to solemnize marriages.
The justices added that no proof was presented to show that the officiant was someone else.
“The legal presumption in favor of the marriage contract must be respected in the absence of clear and convincing evidence to the contrary,” the Court said, stressing that the wife’s later doubts — raised nearly three decades after the ceremony — did not invalidate her earlier good-faith belief.
The SC concluded that the marriage falls within the exception under Article 35(2) of the Family Code and thus remains valid.
In a dissenting opinion, Senior Associate Justice Marvic M.V.F. Leonen maintained that even if the officiant’s lack of authority is excused under the law, the absence of a personal declaration by the spouses during the ceremony — where they publicly take each other as husband and wife — renders the marriage void. He further argued that the irregularities surrounding the ceremony and the officiant’s identity cast reasonable doubt on the marriage’s validity.
