In *Zenaida S. Beso v. Judge Juan Daguman*, the Supreme Court of the Philippines addressed the issue of a judge solemnizing a marriage outside of their designated jurisdiction and failing to properly register the marriage certificate. The Court ruled that Judge Daguman’s actions constituted a neglect of duty and an abuse of authority, emphasizing that judges must adhere strictly to the jurisdictional limits of their office. This decision reinforces the importance of upholding the integrity of the marriage process and ensuring compliance with the legal requirements for solemnization and registration.

When Does ‘I Now Pronounce You…’ Cross Jurisdictional Lines?

This case revolves around a complaint filed by Zenaida S. Beso against Judge Juan Daguman, a municipal judge, for solemnizing her marriage outside of his jurisdiction and for failing to properly register the marriage certificate. Beso alleged that Judge Daguman solemnized her marriage to Bernardito Yman in Calbayog City, which was outside of his designated jurisdiction of Sta. Margarita-Tarangan-Pagsanjan, Samar. Furthermore, she claimed that the judge failed to retain a copy of the marriage contract and did not register it with the local civil registrar, leading to complications after her husband abandoned her.

The core legal question before the Supreme Court was whether Judge Daguman’s actions constituted a breach of his duties as a judge and a violation of the Family Code of the Philippines. The case highlights the importance of adhering to the jurisdictional boundaries of judicial authority and the proper procedures for solemnizing and registering marriages.

The Family Code of the Philippines clearly outlines the requirements for a valid marriage, including who may solemnize a marriage and where it may be solemnized. Article 7 of the Family Code specifies that “[a]ny incumbent member of the judiciary within the court’s jurisdiction” may solemnize marriages. Article 8 further mandates that “[t]he marriage shall be solemnized publicly in the chambers of the judge or in open court…and not elsewhere, except in cases of marriages contracted at the point of death or in remote places…or where both parties request the solemnizing officer in writing”.

In his defense, Judge Daguman argued that he solemnized the marriage in Calbayog City due to pressing circumstances, including the complainant’s scheduled departure for abroad and the presence of sponsors. He also claimed that the failure to register the marriage certificate was due to the husband taking all copies of the document. However, the Court found these justifications insufficient.

The Supreme Court emphasized that judges must not only apply the law but also abide by it. In this case, Judge Daguman exceeded his authority by solemnizing a marriage outside of his jurisdiction. The Court underscored the importance of marriage as a social institution and the need to uphold its integrity by adhering to the legal requirements for its solemnization.

“[M]arriage in this country is an institution in which the community is deeply interested. The state has surrounded it with safeguards to maintain its purity, continuity and permanence. The security and stability of the state are largely dependent upon it. It is the interest and duty of each and every member of the community to prevent the bringing about of a condition that would shake its foundation and ultimately lead to its destruction.”

The Court noted that the exceptions allowing a judge to solemnize a marriage outside their chambers or courtroom did not apply in this case. There was no evidence that either party was at the point of death or in a remote place, nor was there a written request for the marriage to be solemnized elsewhere. Instead, the judge’s actions were driven by a desire to accommodate the complainant, an overseas worker, which the Court deemed an inadequate justification for circumventing the law. The Court’s discussion on Article 23 is equally important in understanding that it is the duty of the solemnizing officer to ensure that the marriage certificate is properly furnished to the parties and sent to the local civil registrar:

“ART. 23. – *It shall be the duty of the person solemnizing the marriage to furnish either of the contracting parties, the original of the marriage contract referred to in Article 6 and to send the duplicate and triplicate copies of the certificate not later than fifteen days after the marriage, to the local civil registrar of the place where the marriage was solemnized.* Proper receipts shall be issued by the local civil registrar to the solemnizing officer transmitting copies of the marriage certificate. The solemnizing officer shall retain in his file the quadruplicate copy of the marriage certificate, the original of the marriage license and, in proper cases, the affidavit of the contracting party regarding the solemnization of the marriage in a place other than those mentioned in Article 8. (Italics supplied)”

The Supreme Court also criticized Judge Daguman for his negligence in failing to ensure the proper registration of the marriage certificate. The Court found his explanation that the husband had taken all copies of the certificate unconvincing, emphasizing that judges must exercise extra care in handling official documents. As previously stated in *Navarro v. Domagtoy*, 259 SCRA 129 [1996]:

A priest who is commissioned and allowed by his ordinary to marry the faithful, is authorized to do so only within the area of the diocese or place allowed by his Bishop. An appellate court justice or a Justice of this Court has jurisdiction over the entire Philippines to solemnize marriages, regardless of the venue, as long as the requisites of the law are complied with. *However, Judges who are appointed to specific jurisdictions may officiate in weddings only within said areas and not beyond.* Where a judge solemnizes a marriage outside his court’s jurisdiction, there is a resultant irregularity in the formal requisite laid down in Article 3, which while it may not affect the validity of the marriage, may subject the officiating official to administrative liability.

To further illustrate the implications of this ruling, consider the following comparative table:

Issue	Judge Daguman’s Actions	Legal Requirements
Jurisdiction	Solemnized marriage outside of his designated jurisdiction	Marriage must be solemnized within the judge’s jurisdiction
Location of Solemnization	Solemnized marriage outside of chambers without valid reason	Marriage should be solemnized in chambers or other specified locations, unless exceptions apply
Registration of Marriage Certificate	Failed to ensure proper registration of marriage certificate	Solemnizing officer must send duplicate and triplicate copies to the local civil registrar

The Supreme Court’s decision in this case serves as a reminder to all judges of the importance of adhering to the legal requirements for solemnizing marriages and exercising caution in handling official documents. The Court’s ruling in *Beso v. Daguman* reinforces the importance of adhering to the jurisdictional boundaries of judicial authority and the proper procedures for solemnizing and registering marriages. By strictly enforcing these requirements, the Court aims to uphold the integrity of the marriage process and protect the interests of the parties involved.

FAQs

What was the key issue in this case?	The key issue was whether Judge Daguman exceeded his authority by solemnizing a marriage outside of his jurisdiction and failing to properly register the marriage certificate.
Where are judges allowed to solemnize marriages?	Judges are generally only allowed to solemnize marriages within their designated court’s jurisdiction, and the ceremony should take place in the judge’s chambers or in open court, unless specific exceptions apply.
What are the exceptions for solemnizing a marriage outside the judge’s chambers?	The exceptions include cases where either party is at the point of death, in remote places, or where both parties request in writing that the marriage be solemnized elsewhere.
What is the solemnizing officer’s responsibility regarding the marriage certificate?	The solemnizing officer is responsible for furnishing the original marriage certificate to the parties and sending duplicate and triplicate copies to the local civil registrar within fifteen days of the marriage.
What was the Court’s ruling in this case?	The Court found Judge Daguman guilty of neglect of duty and abuse of authority and fined him P5,000.00, with a stern warning against future infractions.
Why was Judge Daguman penalized?	Judge Daguman was penalized for solemnizing a marriage outside his jurisdiction without valid justification and for failing to ensure the proper registration of the marriage certificate.
What is the significance of this ruling?	This ruling underscores the importance of judges adhering to the legal requirements for solemnizing marriages and exercising caution in handling official documents.
What government policy was respondent leaning on?	Respondent was leaning on the government policy that overseas worker should deserve more than ordinary official attention under present Government policy.

The Supreme Court’s decision in *Zenaida S. Beso v. Judge Juan Daguman* serves as a crucial reminder to all members of the judiciary to uphold the integrity of their office by strictly adhering to jurisdictional boundaries and legal procedures. This case reinforces the importance of respecting the sanctity of marriage and ensuring that all legal requirements are met during its solemnization and registration.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Zenaida S. Beso v. Judge Juan Daguman, A.M. No. MTJ-99-1211, January 28, 2000