De Guzman, Socrates Jerome 2017-89958

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CASE BRIEF

Style of the case: Aranes v. Occiano

Court: Supreme Court
Judge: Justice Reynato Puno
Facts and Procedural History:
On February 17, 2000, respondent Judge Salvador Occiano solemnized the marriage of petitioner
Mercedita Aranes and Dominador Orobio without the requisite marriage license and at Nabua, Camarines
Sur which is outside his territorial jurisdiction. Upon Dominador Orobio’s death, Aranes found that her
right to inherit Orobia’s property, as well as to receive Orobia’s pensions, cannot be recognized as their
marriage was void ab initio for lacking the requisite marriage licence. With this, petitioner charges
respondent judge with Gross Ignorance of the Law and that sanctions be imposed against him for his illegal
acts and unethical misrepresentation.
In his defense, respondent judge averred that he was assured by the petitioner that all marriage
documents have been completed. In addition, petitioners requested that the ceremony be solemnized in
Nabua as Orobia already has difficulty walking. He further avers that before he started the ceremony, he
found out that the couple lacked a marriage license and suggested that the marriage be moved so as to
comply with all necessary requisites. However, due to the earnest pleads of the petitioner, he proceeded to
solemnize the marriage out of human compassion. He further alleged that the couple assured him that they
will give the license later that day.
Upon finding the reply of the respondent judge, Aranes signed an affidavit of desistance and agreed
with the facts presented by Occiano.
The Office of the Court Administrator found the respondent judge guilty of solemnizing the
marriage without a marriage license and for doing so outside his territorial jurisdiction. A fine of P5,000
was recommended to be imposed.
Issues:
1. Whether or not sanctions should be imposed on respondent judge for solemnizing the marriage
outside his territorial jurisdiction
2. Whether or not sanctions should be imposed on respondent judge for solemnizing the marriage
without a marriage licence
Judgment:
Respondent Judge Salvador M. Occiano, Presiding Judge of the Municipal Trial Court of Balatan,
Camarines Sur, is fined P5,000.00 pesos with a STERN WARNING that a repetition of the same or similar
offense in the future will be dealt with more severely.
Holding:
1. YES. The Court cited the Judiciary Reorganization Act of 1980 which states that the authority of
the regional trial court judges and judges of inferior courts to solemnize marriages is confined to
their territorial jurisdiction as defined by the Supreme Court. In addition, the court settled in
De Guzman, Socrates Jerome 2017-89958
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Navarro vs. Domagtoy: “that 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
courts 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.”

2. YES. The Court cited People v. Lara wherein it was settled that a marriage which preceded the
issuance of a license is void in so far as the license itself gives the solemnizing officer the authority
to solemnize the ceremony.
Dicta:
In the first issue, it was held in Navarro v. Domagtoy that a priest who is commissioned and allowed
by his local ordinance to marry the faithful is authorized to do so only within the area or 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. The court further held that the judiciary should be composed of experts or at least people proficient
in the law more than the ordinary layman.
As for the second issue, Respondent judge cannot be exculpated despite the Affidavit of Desistance
filed by petitioner. This Court has consistently held in a catena of cases that the withdrawal of the complaint
does not necessarily have the legal effect of exonerating respondent from disciplinary action. Otherwise,
the prompt and fair administration of justice, as well as the discipline of court personnel, would be
undermined.