### Facts:
**Initial Filing:**
– **Petitioner:** Raquel G. Kho
– **Respondents:** Republic of the Philippines and Veronica B. Kho
– **Date of Original Marriage:** June 1, 1972
– **Legal Action:** Petition for Declaration of Nullity of Marriage filed at the RTC of Oras, Eastern Samar.
**Timeline of Events:**
1. **May 31, 1972:** Petitioner’s parents instructed Eusebio Colongon, a clerk in the municipal treasurer’s office, to prepare necessary papers for an intended midnight marriage on June 1, 1972.
2. **June 1, 1972:**
– **3:00 AM:** Marriage solemnized between the petitioner and respondent.
– **Venue:** Adjacent to a town plaza after a public dance concluded.
3. **Claim by Petitioner:** No marriage license was issued or obtained, asserting that the marriage is null and void.
4. **May 1997:** Petition for annulment filed, asserting the marriage lacked a license.
**Procedural History:**
1. **RTC Decision:**
– **Date:** September 25, 2000
– **Finding:** Marriage license was absent, marriage declared null and void ab initio.
2. **CA Appeal:**
– **Respondent’s Appeal:** To the Court of Appeals (CA-G.R. CV No. 69218).
– **CA Decision:** March 30, 2006, reversed RTC and declared marriage valid based on presumption of a marriage license.
– **CA Resolution on Motion for Reconsideration:** January 14, 2009, denied petitioner’s motion.
3. **Petition for Review on Certiorari:** Filed to the Supreme Court challenging CA’s decision and raising issues of erroneous reliance on presumptions and dismissal of petitioner’s proofs.
### Issues:
1. **Ethical Dimensions:** Whether the CA erred by considering petitioner’s alleged ethical failings as influencing the judgment.
2. **Lapse of Time:** Whether the CA erred by considering the elapse of 25 years as affecting the nullity of the marriage.
3. **Documentary Evidence vs. Presumptions:** Whether CA correctly disregarded petitioner’s evidence about lack of marriage license and instead relied on presumptions of validity.
4. **Reversal of RTC’s Judgement:** Whether the CA was correct in reversing RTC’s nullification of the marriage due to the absence of a marriage license.
### Court’s Decision:
**Supreme Court Analysis:**
1. **Marriage License Requirement:**
– Articles 53, 58, and 80(3) of the Civil Code mandate a marriage license.
– Certification from the Municipal Civil Registrar of Arteche that no license was issued established prima facie proof of absence of a marriage license, shifting the burden to respondent to prove otherwise.
2. **Ethics and Motive:**
– Motivations behind seeking the annulment were deemed irrelevant to the legal requirement of a valid marriage license.
3. **Presumptions vs. Factual Evidence:**
– The presumption of marriage validity was overcome by petitioner’s evidence. Respondent failed to produce a marriage license or credible related documents.
4. **Reinstatement of RTC Decision:**
– Given respondent’s failure to prove the issuance of a license, the Court reinstated the RTC’s nullification of the marriage.
**Final Ruling:**
– **Supreme Court:** Granted petition, reversed CA’s decision, and reinstated RTC’s decision declaring the marriage null and void ab initio.
### Doctrine:
– **Marriage License Requirement:** Absence of a marriage license renders a marriage null and void ab initio as per Articles 53, 58, and 80(3) of the Civil Code of the Philippines.
– **Burden of Proof:** Once prima facie evidence of no marriage license is presented, the burden shifts to the party claiming validity to prove otherwise.
### Class Notes:
– **Civil Code Requirement:** Article 53 – Essential Requisites; Articles 58 and 80 – Mandatory Marriage License.
– **Burden of Proof:** Certification from Local Civil Registrar can establish prima facie non-existence of a marriage license. Parties claiming validity must produce the license.
– **Presumption Combat:** A certification of no record can override the presumption of marriage validity when properly supported.
– **Legal Maxims:** “The one who alleges must prove” – Mere assertion without proof is inadequate.
### Historical Background:
This case underscores the stringent procedural and substantive requirements for marriage validity under Philippine law as dictated by the Civil Code, pre-Family Code era. It illustrates the judiciary’s role in upholding legal requisites such as marriage licenses, irrespective of the elapsed time or the motives behind seeking marital dissolution. It also highlights the evolution from the Civil Code to the Family Code in ensuring legal consistency and reinforcing judicial scrutiny over matrimonial regulations.
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