Republic v. Court of Appeals and Angelina M. Castro

Summary

This case involves a petition for declaration of nullity of marriage filed by Angelina Castro against her husband Edwin Cardenas, claiming no marriage license was issued prior to their 1970 marriage. The Regional Trial Court denied the petition, finding the civil registrar's certification of non-existence insufficient. The Court of Appeals reversed, declaring the marriage void. The Supreme Court affirmed, holding that a certification of 'due search and inability to find' from the civil registrar constitutes adequate proof under Rule 132, Section 29 of the Rules of Court. The Court emphasized that marriage licenses are essential requisites under the New Civil Code, and their absence renders marriage void ab initio. The decision establishes important precedent on the probative value of negative certifications from public records custodians in proving non-existence of required documents for valid marriages.