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RENE RONULO v. PEOPLE

FACTS:

Joey Umadac and Claire Bingayen were scheduled to marry on March 29, 2003 at the Sta. Rosa Catholic Parish Church. However, the officiating priest refused to solemnize the marriage because the couple failed to secure a marriage license. As a recourse, Joey and Claire, along with their parents and guests, went to the Aglipayan Church and requested petitioner Fr. Rene Ronulo, an Aglipayan priest, to perform a ceremony. Despite knowing that the couple had no marriage certificate, Fr. Ronulo agreed. He conducted the ceremony in the presence of the couple, their parents, sponsors, and guests. An information for violation of Article 352 of the Revised Penal Code (RPC) was filed against Fr. Ronulo for allegedly performing an illegal marriage ceremony. The Municipal Trial Court found Fr. Ronulo guilty and imposed a fine. The Regional Trial Court affirmed the decision, as did the Court of Appeals. Fr. Ronulo filed a petition for review on certiorari before the Supreme Court, challenging the CA decision.

ISSUES:

  1. Whether the alleged "blessing" by the petitioner is tantamount to the performance of an "illegal marriage ceremony" punishable under Article 352 of the RPC, as amended.

  2. Whether the personal declaration by the contracting parties that they take each other as husband and wife in the presence of not less than two witnesses satisfies the requirements of a marriage ceremony.

  3. Whether the principle of separation of church and State precludes the State from qualifying the church "blessing" into a marriage ceremony.

  4. Whether the lack of a marriage certificate negates the petitioner's criminal liability.

  5. Whether the non-filing of a criminal complaint against the couple negates the petitioner's criminal liability.

  6. What is the proper penalty for the violation of Article 352 of the RPC.

RULING:

  1. The alleged "blessing" by the petitioner is considered a performance of an "illegal marriage ceremony" punishable under Article 352 of the RPC, as amended.

  2. The personal declaration by the contracting parties that they take each other as husband and wife in the presence of not less than two witnesses satisfies the requirements of a marriage ceremony.

  3. The principle of separation of church and State does not preclude the State from qualifying the church "blessing" into a marriage ceremony.

  4. The lack of a marriage certificate does not negate the petitioner's criminal liability as it is not included in the requirements for conducting a marriage ceremony according to the Family Code.

  5. The non-filing of a criminal complaint against the couple does not negate the petitioner's criminal liability as it is not an element of the crime under Article 352 of the RPC.

  6. The penalty for the violation of Article 352 of the RPC is the one imposed under Section 44 of the Marriage Law, which provides for a fine of not more than two hundred pesos or imprisonment for not more than one month, or both.

PRINCIPLES:

  • The elements of the crime punishable under Article 352 of the RPC, as amended, are the authority of the solemnizing officer and the performance of an illegal marriage ceremony.

  • No prescribed form or religious rite for the solemnization of marriage is required under Article 6 of the Family Code, but it is necessary for the contracting parties to appear personally before the solemnizing officer and declare in the presence of not less than two witnesses that they take each other as husband and wife.

  • The presence of the minimum requirements of law, constitutive of a marriage ceremony, qualifies a "blessing" into a "marriage ceremony" as contemplated by Article 3(3) of the Family Code and Article 352 of the RPC, as amended.

  • The principle of separation of church and State allows religions or sects the freedom to conduct their respective marital rites, subject to the core requirements of the law being observed.

  • Marriage is an inviolable social institution, and the State has paramount interest in enforcing its constitutional policies and preserving the sanctity of marriage. The State has the power to enact laws and regulations, such as Article 352 of the RPC, as amended, to penalize acts that result in the disintegration and mockery of marriage.

  • The presence of a valid marriage certificate is an essential requisite of marriage.

  • Knowledge of the absence of the essential and formal requirements of marriage negates the defense of good faith.

  • A marriage certificate is not included in the requirements provided by the Family Code for determining if a marriage ceremony has been conducted.

  • Non-filing of a criminal complaint against the couple does not negate the criminal liability of a person who conducted an illegal marriage ceremony.

  • The penalty for the violation of Article 352 of the RPC is determined by the penalty provisions of the Marriage Law.