Certain marriages which the place of celebration is not easy to determine:

1. Proxy marriages A marriage by proxy is one where one of the parties is merely represented at the ceremony by a friend or delegate.

It should be noted that the place where the proxy appears is considered where the marriage is celebrated.
If celebrated in the Philippines the marriage is void. Article 6 of the Family Code requires the presence of both parties. It is said however that the rule holds true only in cases where the marriage is between Filipinos or between a Filipino and a foreigner. In case the contracting parties are both foreigners, then it would be a valid marriage provided their national law considers is such. If celebrated abroad the rule is lex loci celebrationis, whether the marriage is between Filipinos, foreigners or mixed.This is of course subject to the usual exceptions (highly immoral etc.) and subject to special provisions as may be found in special laws (e.g., immigration laws for purpose of immigration). Example: American case, a turkish immigrant to the US was able to marry by proxy a woman living in Turkey, thereby enabling her to join him in the US.

2. Common Law Marriage accomplished by cohabitation and agreement without formal ceremony. If valid in the State where the parties cohabited while holding themselves out as man and wife, it is given recognition in sister States which do not permit this informal method of entering into the marital status. Common law marriages are not recognized under the Philippine internal law. Eugenio vs. Velez 3. Marriage on board a vessel on the high seas. Gen. Rule: Law of the Flag of the Ship governs formal validity of marriage. Exception: Domicile of the owner, where there is no national of the Flag of the Ship. the greatest amount of control over the ship is her owner, and the State most closely connected with the owner.

Substantive Validity Under all legal systems, the permission for marry is subject to certain substantive requirements, the absence of which render the marriage void or voidable. Art. 2 of the Family Code. 1. Legal Capacity of contracting parties which must be a man and a woman 2. Consent freely given in the presence of the soleminizing officer.

Marriage involving foreign element.

Where a marriage is considered primarily as a contract, the law of the place of celebration is considered decisive. Where marriage is treated primarily as a status and an institution , where the state have a vital interest, it is the law of their domicile that is considered controlling from the point of view of the State following that principle and it is their nationality from the point of view of many civil law countries that is considered controlling. US and Philippines attempt to combine both principles.

Example: Polygamous and incestous Marriage. -