Melad v. Melad G.R. No. 267998 (Supreme Court, Second Division, Promulgated April 23, 2025) (CASE DIGEST)

Facts

Eloisa Maliwat-Melad (Petitioner) and Amancio Reyes Melad (Private Respondent) were married on March 23, 1990, in Tarlac City, and produced three children. The marriage contract identified the solemnizing officer as Judge Conrado De Gracia. In 2018, Eloisa filed a petition seeking to declare the marriage null and void based on the lack of authority of the solemnizing officer. Eloisa alleged that the person who solemnized the marriage was actually a certain Roselio Florendo (Florendo), not Judge De Gracia, and presented pictures. The Regional Trial Court (RTC) and the Court of Appeals (CA) denied the petition, holding that the marriage contract was a public document serving as prima facie proof of marriage, and Eloisa failed to present clear and convincing evidence to rebut the prima facie presumption of validity.

Issues

1. Whether the Petitioner successfully proved, by clear and convincing evidence, that her marriage was void ab initio due to the lack of legal authority of the solemnizing officer.
2. Whether the good faith exception under Article 35(2) of the Family Code applies, thereby validating the marriage even if the solemnizing officer lacked authority.

Ruling

The petition is unmeritorious.

Petitioner failed to prove, by clear and convincing evidence, that her marriage to private respondent was void ab initio on the ground of lack of authority of the solemnizing officer.

ACCORDINGLY, the petition is DISMISSED. The October 27, 2022 Decision and the May 17, 2023 Resolution of the Court of Appeals in CA-G.R. CV No. 117590, upholding the March 1, 2021 Decision of Branch 11, Family Court, Tarlac City is AFFIRMED. SO ORDERED.

Essential Elements of Jurisprudence

1. Marriage as a State-Protected Institution: Marriage is a special contract governed by law, not merely by the stipulations of the contracting parties, and the State protects its purity, continuity, and permanence.
2. Quantum of Proof for Nullity: In nullity cases, the required quantum of proof is clear and convincing evidence, which is a higher standard than preponderance of evidence but less stringent than proof beyond reasonable doubt. A party who alleges an irregularity has the burden of proving it with this quantum of evidence.
3. Prima Facie Presumption of Validity: A marriage contract, being a public document, serves as prima facie proof of marriage and gives rise to a legal presumption in favor of the solemnizing officer’s authority and the marriage’s validity, which must be upheld unless rebutted by clear and convincing evidence.
4. Void Marriages (Formal Requisite): The authority of the solemnizing officer is a formal requisite of marriage (Article 3, Family Code). The absence of this formal requisite renders the marriage void ab initio (Article 4, Family Code).
5. The Good Faith Exception (Curative Provision): A marriage solemnized by a person without legal authority is void, EXCEPT if one or both parties contracted the marriage believing in good faith that the solemnizing officer had the legal authority to do so (Article 35, Family Code). If the petitioner failed to prove the solemnizing officer lacked authority, or if the petitioner was found to have been in good faith that the officer had authority since the marriage’s inception in 1990, the marriage remains valid.

Sample Q&A

Question: Elara files a petition in 2025 seeking to declare her 1995 marriage void ab initio, alleging that the solemnizing officer lacked legal authority, relying on photographs showing a person other than the judge listed on the marriage certificate. Elara admits that, at the time of the wedding, she believed the person who officiated was indeed the judge, relying only on the judge’s name printed on the contract. If the court finds that Elara failed to present clear and convincing evidence that the solemnizing officer was unauthorized, or alternatively, if the officer was unauthorized but Elara sincerely believed he was authorized, what should the court rule? Cite the relevant Family Code provisions.

Answer: The court should dismiss the petition and uphold the validity of the marriage.

Rationale:

1. Burden of Proof (Clear and Convincing Evidence): The petitioner bears the burden of proving the lack of the formal requisite (authority of the solemnizing officer, pursuant to Article 3 and Article 4 of the Family Code) by clear and convincing evidence. Failing to present such evidence means the legal presumption of the validity of the public document (the marriage contract) prevails.
2. Good Faith Exception (Article 35): Even assuming arguendo that the solemnizing officer was unauthorized, the marriage is not void if Elara contracted the marriage in good faith believing that the officer had the legal authority to solemnize the marriage. Since Elara admitted that she believed the officiant had authority at the time of the marriage, the marriage falls under the exception provided in Article 35(2) of the Family Code, which saves the marriage from being declared void ab initio.

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