Republic v. Lazaro

Summary

This case involves the declaration of nullity of marriage between Reynold Q. Lazaro and Jackelin L. Navarro-Lazaro who married on August 5, 2000. The core issue was whether their marriage was validly contracted with a proper marriage license. Reynold discovered that Marriage License No. 4025408, which appeared on their marriage certificate as issued by Imus, Cavite Civil Registrar, was actually non-existent. The Municipal Civil Registrar of Imus, Cavite certified that no marriage license application was made by the couple. All three court levels—RTC, CA, and SC—consistently ruled that the marriage was void ab initio due to the absence of a valid marriage license, which is a formal requisite under the Family Code. The Supreme Court emphasized that certifications from civil registrars enjoy probative value as custodians of marriage license records, and the Republic failed to present convincing evidence to rebut this certification. The case reaffirms the fundamental principle that marriages solemnized without valid marriage licenses are void from the beginning under Philippine family law.