Ronulo vs People of the Philippines

G.R. no. 182438 July 2, 2014

Brion, J.:
Facts:
Petitioner is Rene Ronulo seeking to reverse the CA decision in CR no. 31028 which
upheld the decision of the RTC Branch 18, Batac, Ilocos Norte. Rene Ronulo is an
Aglipayan priest, who officiated a wedding between Joey Umadac and Claire
Bingayen who did not have a marriage license. The two were rejected by the Sta.
July 2, 2014 Rosa Catholic Parish Church of San Nicolas, which led them to Father Rene Ronulo
who agreed to perform the ceremony knowing that the already-dressed couple had
no marriage certificate. A violation of Art 352 of the Revised Penal Code was filed
against Ronulo. He pleaded not guilty, saying that it was only an act of blessing and
not a marriage. After witnesses testified that they saw the couple exchange their
vows, the mother of Joey was given a certificate that no marriage license was issued
to the couple by the Municipal Local Civil Registrar of Ilocos Norte. The MTC found
Father Ronulo guilty of violating Art 32 of the RPC. He was fined 200 pesos pursuant
to Sec 44 of Act No 3613. The RTC affirmed the findings of the MTC but said the fine
must be based on sec 39, not sec 44. The CA then affirmed the RTC ruling bec:
Standards of marriage are: 1) parties must appear personally before the
solemnizing officer and 2) they should declare that they take each other as
husband and wife before at least 2 people of legal age.
The presence of a marriage certificate is not a requirement in the marriage
ceremony
The priests liability under Art 352 of the RPC is not dependent on the
liability of the couple under Art 350 of the RPC
The basis for the fine is Art 44, not Art 39
Petitioner argues:
Art 352 of RPC is vague, does not define what illegal marriage ceremony is
Prosecution failed to prove that the couple verbally took each other as
husband and wife
Separation of Church and State which doesnt allow the state to interpret
blessing and turn it into a marriage ceremony
Petitioner had no criminal intent and conducted the blessing in good faith
Not filing a case on the couple prevents a case against him
Art 352 of the RPC does not provide penalty and the present case is not
covered by sec 44 of the Marriage Law

Issue:
Whether or not CA decision to uphold the RTCs decision was correct
Ruling:
The decision of the Supreme Court does not give merit to the petitioner. The CA did not err in
imposing the penalty and for upholding the RTCs decision
Art 352 of the RPC penalizes the solemnizing officer for conducting illegal ceremonies
-1) authority of the solemnizing officer and 2) his performance of an illegal ceremony are both
clearly satisfied. Ronulo indeed does have authority to solemnize
Art 3(3) and 6 of the Family code
 -no prescribed form of marriage is required. It mirrors Art 6 of the Family Code which gives
the standard of a 1) solemnizing officer and the appearance of the parties and 2) taking each
other as husband and wife in front of witnesses of legal age. Joeys mom testified to the
appearance of the parties and that they took each other as husband and wife.
* a judge may examine or cross examine a witness and propound clarificatory questions to
test their credibility, this is not insinuating or leading a witness
The defense failed to discredit the witnesses Joseph and Mary Ann who were at the wedding
of any ill-motive to testify against Ronulo
The state is not interfering with the church, this is proven by Art 6 of the Family Code that
allows any form of marriage
Art 15 of the Constituion
-marriage is not a mere contract, it is a social institution in which the State is invested. The
state must preserve the sanctity of marriage and not allow its mockery.
Art 3(3) of the Family code
-a marriage must have a valid marriage certificate. The petitioner knew their lack of a
marriage cert, and still conducted the blessing. It was therefore illegal and the petitioner
cannot argue good faith
- lack of marriage certificate does not prevent a marriage ceremony from happening
Art 352 of the RPC (penalizing an authorized solemnizing officer who performs any illegal
marriage ceremony)
-Not filing a case on the couple does not negate the liability petitioner
-provision must be imposed with the Marriage Law. The penalty of the Marriage Law is on sec
44 (violating Art 352 of the RPC), not 39 (refusal to exhibit authorization of illegal marriage)