CASE BRIEF

Style of the Case: Mercedita Mata Aranes vs Judge Salvador M. Occiano

Court: First Divison, Supreme Court

Judge: Justice Puno

Facts and Procedural History:

Mercedita Mata Aranes (petitioner) charges Judge Salvador M. Occiano (respondent

judge) with Gross Ignorance of the Law.

Respondent judge is the presiding judge of the Municipal Trial Court of Balatan,
Camarines Sur.

Petitioner alleges that on Feb 17 2000, respondent judge solemnized her marriage
to her late groom Dominador B. Orobia without the requisite marriage license and in
Nabua, Camarines Sur, outside his territorial jurisdiction.

Because the marriage was a nullity, the petitioner could not inherit the vast
properties left by Orobia upon his death. She was also deprived of receiving Orobias
pensions as he was a retired Commodore of the Philippine Navy.

In his Comment (July 5, 2001) the respondent judged averred that he was requested
by Juan Arroyo to solemnize the marriage of the parties on Feb 17, 2000. He was
told that Orobia had difficulty walking and could not travel to the MTC of Balatan,
Camarines Sur so respondent judge acceded to the request that he travel to Nabua
to solemnize the marriage.

Upon discovery that the parties did not have all the required documents, respondent
judge suggested resetting the wedding date but he was asked to solemnize the
wedding anyway because of the guests and the preparations already in place. After
the solemnization, he reminded the parties of the need for the marriage license and
that failure to give it to him would render the marriage void.

Respondent judge denies that he told the parties that their marriage was valid
despite the absence of a marriage license.

Petitioner filed affidavit of desistance dated Aug 28, 2001 where she stated that all
the respondent judge said was correct and that she filed the administrative case out
of anger.

In the records of the case, petitioner and Orobia did file for application of marriage
license, which they did not claim. They could not claim it any way, since Orobia
failed to submit the Death Certificate of his previous spouse.
The Office of the Court Administrator found the respondent judge guilty of
solemnizing a marriage without a duly registered marriage license and of doing so
outside of his official jurisdiction.

Issues:

W/N the respondent judge is guilty of solemnizing the marriage without a marriage
license and at a place outside his jurisdiction.

W/N the respondent judge can be exculpated with the Affidavit of Desistance filed
by the petitioner.

Judgment: Respondent judge is found guilty of solemnizing a marriage without a

marriage license and outside his jurisdiction.

Holding:

Yes, because judges who are appointed to specific jurisdictions may only officiate
weddings within said areas and not beyond.

No, because the withdrawal of the complaint case does not necessarily have the
legal effect of exonerating respondent from disciplinary action.

Discussion (and Dicta):

There is precedent for the case at bar in Navarro vs Domagtoy. The Court ruled then
that when judges solemnize marriages outside their jurisdiction, while the validity
of the marriage is not affected, the officiating official is subject to administrative
liability.

In People vs Lara, it was held that a marriage without the issuance of a marriage
license is void and the subsequent issuance of a marriage license cannot render
valid the marriage.

Written by: Raissa N. Matunog