MERCEDITA MATA ARAÑES

vs.
JUDGE SALVADOR M. OCCIANO
A.M. No. MTJ-02-1390            April 11, 2002
(Formerly IPI No. 01-1049-MTJ)

FACTS: Mercedita Mata Aranes charged Judge Salvador Occiano for Gross Ignorance of Law on
May 23, 2001. Aranes alleged that Judge Occiano of MTC Balatan solemnized the marriage of
Aranes and Dominador Orobia without the requisite marriage license. On the other hand, Judge,
assuming that all the documents to the marriage were complete, he agreed to solemnize the
marriage as per request of Juan Arroyo in Nabua, Camarines Sur (not within his jurisdiction as
Judge) because Orobia has diffilculty walking and could not stand the rigors of travelling to Balatan.
Her husband passed away but Aranes was not recognized as his inheritor and a beneficiary of his
pensions because the marriage was in fact, not entered in the civil registry.

ISSUES:
1. Did Judge acted with Gross Ignorance of the Law in solemnizing the marriage in Nabua?
2. Did Judge acted with Gross Ignorance of the Law in solemnizing the marriage without the
requisite marriage license?

RULING:
1. The territorial jurisdiction of respondent judge is limited to the municipality of Balatan,
Camarines Sur. Citing the case Navarro vs Domagtoy, “However, judges who are
appointed to specific jurisdictions, may officiate in weddings only within said areas
and not beyond. Where a judge solemnizes a marriage outside his court's jurisdiction,
there is a resultant irregularity in the formal requisite laid down in Article 3, which
while it may not affect the validity of the marriage, may subject the officiating official
to administrative liability."

2. YES. Except in cases provided by law, it is the marriage license that gives the solemnizing
officer the authority to solemnize a marriage.