FACTS:

This case involves a dispute over the validity of a reconstructed Marriage Contract and the authenticity of the signature of Judge Moya in an Order granting a petition for adoption. The petitioner claimed to be the surviving spouse of the deceased based on the reconstructed Marriage Contract, while the respondent claimed to be the legally adopted son of the deceased and presented an Order of adoption. The trial court observed irregularities in the execution of the reconstructed Marriage Contract. The authenticity of Judge Moya's signature in the Order was also questioned. The trial court consulted two handwriting experts, one who found significant differences in the signatures and concluded them to be different, while the other found significant similarities and declared the signature to be genuine. With conflicting findings, the trial court ruled in favor of the respondent, declaring him the legally adopted child and invalidating the reconstructed Marriage Contract. The Court of Appeals affirmed the trial court's decision, giving great weight to the opinion of handwriting experts and emphasizing the respect accorded to the trial court's findings of fact. The petitioner filed a Petition for Review before the Supreme Court, challenging the validity of the marriage. The Supreme Court will determine whether the marriage was indeed valid.

ISSUES:

a) Whether the marriage between the plaintiff Tomasa Vda. De Jacob and deceased Alfredo E. Jacob was valid.

b) Whether defendant Pedro Pilapil is the legally adopted son of Alfredo E. Jacob.

RULING:

a) The marriage between Tomasa Vda. De Jacob and Alfredo E. Jacob was valid. The Supreme Court ruled that the absence of a marriage license was excusable due to their cohabitation for at least five years, making the marriage exceptional under Article 76 of the Civil Code. The due execution and loss of the marriage contract were sufficiently proven, allowing secondary evidence to establish the validity of the marriage.

b) Pedro Pilapil is not the legally adopted son of Alfredo E. Jacob. The Court found that the authenticity of Judge Moya's signature on the contested Adoption Order was not sufficiently established and was rebutted by both Judge Moya's testimony and expert findings, thus declaring the claimed adoption nonexistent.

PRINCIPLES:

• Void vs. Voidable Marriages A void marriage may be subjected to collateral attack, while a voidable one may only be assailed in a direct proceeding.

• Exceptional Marriages Under Article 76 of the Civil Code, cohabitation for at least five years without a marriage license can validate a marriage.

• Secondary Evidence Rule If the original writing is lost or destroyed, secondary evidence is admissible upon proof of its execution and loss.

• Proof of Marriage Marriage can be proven by any competent and relevant evidence, including testimonial evidence from parties or witnesses to the marriage.

• Presumption in Favor of Marriage Societal norms and legal presumptions favor legalizing marriages, and cohabitation presumes a lawful marriage contract.

• Burden of Proof The burden of proof in establishing adoption lies with the person claiming such relationship.