In Diaz-Salgado v. Anson, the Supreme Court addressed the critical issue of marriage validity when a marriage license is absent. The Court reversed the Court of Appeals’ decision, ruling that a marriage contract explicitly stating the absence of a marriage license renders the marriage void ab initio, unless proven otherwise. This case clarifies the burden of proof in establishing a valid marriage and the property rights arising from unions without proper legal formalities. The decision underscores the importance of adhering to the formal requisites of marriage, especially the marriage license, and provides guidance on how properties acquired during such unions are to be divided.

From Common-Law to Courtroom: Contesting Marriage Validity and Estate Claims

The case revolves around Luis Anson’s claim to be the surviving spouse of Severina de Asis-Anson, seeking to annul deeds of sale and an extra-judicial settlement that allegedly deprived him of his share in their conjugal properties and inheritance. Luis presented a marriage contract as proof of his marriage to Severina. However, the marriage contract stated that no marriage license was exhibited to the solemnizing officer, citing Article 77 of the Civil Code as the reason. Jo-Ann Diaz-Salgado and Maria Luisa Anson-Maya, Severina’s daughters from previous relationships, contested the validity of the marriage, arguing that Luis and Severina had a common-law relationship terminated by a Partition Agreement, and that Luis had remarried in the United States. The central legal question is whether the marriage between Luis and Severina was valid, and consequently, whether the properties in question were conjugal or Severina’s exclusive properties.

The resolution of this case hinges on the validity of Luis and Severina’s marriage, solemnized on December 28, 1966. Under the Civil Code, which was in effect at the time, a valid marriage license is a mandatory requisite for marriage, as stipulated in Article 53. The absence of a marriage license renders a marriage void ab initio, as per Article 80(3), except in marriages of exceptional character. These exceptional marriages, detailed in Articles 72 to 79 of the Civil Code, include marriages in articulo mortis, in remote locations, consular marriages, ratification of marital cohabitation, religious ratification of a civil marriage, Mohammedan or pagan marriages, and mixed marriages.

In this case, the marriage contract explicitly stated that no marriage license was presented because the marriage was purportedly of an exceptional character under Article 77 of the Civil Code. Article 77 pertains to a religious ceremony ratifying a civil marriage, exempting the parties from needing a marriage license for the religious ceremony. However, the Supreme Court noted that Article 77 applies only when the parties are already civilly married and the subsequent ceremony is purely religious. Here, the ceremony on December 28, 1966, was the only marriage ceremony between Luis and Severina, making Article 77 inapplicable, and necessitating a marriage license for validity. The marriage, therefore, did not fall under any exceptional character.

The burden of proving the existence or non-existence of the marriage license became a critical point. Given the marriage contract’s declaration that no marriage license was exhibited, the burden shifted to Luis to prove they had secured a marriage license. Luis, however, relied on the presumption of the marriage’s validity, which the Court found insufficient against the prima facie evidence from the marriage contract. The Court emphasized that if a marriage license existed, its absence on the marriage contract needed explanation, and the original or a copy of the license should have been presented. Luis himself admitted uncertainty about applying for the license, further weakening his claim.

The Court distinguished this case from Geronimo v. CA, where the validity of a marriage was upheld despite the absence of the marriage license number on the marriage contract. In Geronimo, there was no statement indicating the marriage was of an exceptional character, and a copy of the marriage contract on file with the National Archives showed the marriage license number. In contrast, the marriage contract of Luis and Severina contained a false statement claiming an exceptional character, and Luis failed to provide any credible evidence of a marriage license. The Supreme Court quoted Alcantara v. Alcantara, stating that to be considered void due to the absence of a marriage license, “the absence of such marriage license must be apparent on the marriage contract, or at the very least, supported by a certification from the local civil registrar that no such marriage license was issued to the parties.”

In Republic of the Philippines v. Dayot, the Supreme Court had also declared a marriage void when solemnized without a marriage license, based on a fabricated claim of exceptional character. Similarly, in the present case, the Court ruled that the false claim that the marriage was of an exceptional character invalidated the marriage. Citing Niñal v. Bayadog, the Court asserted, “The parties should not be afforded any excuse to not comply with every single requirement and later use the same missing element as a pre-conceived escape ground to nullify their marriage. There should be no exemption from securing a marriage license unless the circumstances clearly fall within the ambit of the exception.”

The Court then addressed the validity of the Partition Agreement executed by Luis and Severina in 1980, which divided their properties. Luis argued for its annulment, asserting that such separation of property requires judicial approval to be effective. The Court referred to Valdes v. RTC, Branch 102, Quezon City, noting that in a void marriage, property relations during cohabitation are governed by Article 147 of the Family Code, which is a remake of Article 144 of the Civil Code. Article 147 provides that wages and salaries shall be owned equally, and property acquired through work or industry shall be governed by co-ownership rules. Given the absence of a valid marriage license, Article 147 applied, and the provisions on co-ownership under the Civil Code governed the partition of their properties.

Under Article 496 of the Civil Code, partition may be made by agreement between the parties or through judicial proceedings. The law does not mandate judicial approval for the agreement to be valid. As Luis admitted to the Partition Agreement’s existence, due execution, and authenticity, and it was uncontroverted that he received his share as stipulated, the Court found no grounds to invalidate the agreement.

Ultimately, the Court emphasized that while a certification from the local civil registrar could validate the absence of a marriage license, it is not the sole proof. The explicit statement in Luis and Severina’s marriage contract that no marriage license was presented, coupled with the fabricated claim of an exceptional character, were compelling circumstances. The Court also highlighted Luis’s failure to assert his marriage during Severina’s lifetime and his subsequent marriage abroad, further undermining his claims. For these reasons, the Court granted the petition, reversed the Court of Appeals’ decision, and dismissed the complaint.

FAQs

What was the key issue in this case?	The key issue was whether the marriage between Luis Anson and Severina de Asis-Anson was valid, given the absence of a marriage license as stated in their marriage contract. This determined Luis’s rights to the conjugal properties and inheritance.
What did the marriage contract state regarding the marriage license?	The marriage contract stated that no marriage license was exhibited to the solemnizing officer. It falsely claimed that the marriage was of an exceptional character under Article 77 of the Civil Code.
What is required for a marriage to be valid under the Civil Code?	Under the Civil Code, a valid marriage requires legal capacity of the contracting parties, their consent, the authority of the person performing the marriage, and a marriage license, except in marriages of exceptional character.
What are considered marriages of exceptional character?	Marriages of exceptional character include those in articulo mortis (at the point of death), in remote places, consular marriages, ratification of marital cohabitation, religious ratification of a civil marriage, Mohammedan or pagan marriages, and mixed marriages.
What is the effect of a void marriage on property relations?	In a void marriage, the property relations during cohabitation are governed by Article 147 of the Family Code, which provides that wages and salaries are owned equally, and property acquired through work or industry is governed by co-ownership rules.
How can co-owned property be divided in a void marriage?	Co-owned property in a void marriage can be divided by agreement between the parties or through judicial proceedings. Judicial approval is not mandatory for the agreement to be valid.
What was the significance of the Partition Agreement in this case?	The Partition Agreement was significant because it showed that Luis and Severina had already divided their properties by mutual agreement. Since Luis admitted its validity and received his share, the Court upheld the agreement.
What evidence can prove the absence of a marriage license?	The absence of a marriage license can be proven by a certification from the local civil registrar or when the marriage contract itself states that no marriage license was exhibited, as in this case.

In conclusion, Diaz-Salgado v. Anson underscores the critical importance of adhering to the formal requisites of marriage, particularly the marriage license, for a union to be legally recognized. The decision provides clarity on the burden of proof in establishing the validity of a marriage and the property rights arising from unions without proper legal formalities. The Supreme Court’s ruling serves as a reminder of the legal implications of non-compliance with marriage requirements, affecting property rights and inheritance claims.

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: JO-ANN DIAZ-SALGADO VS. LUIS G. ANSON, G.R. No. 204494, July 27, 2016