RENE RONULO vs.

 PEOPLE OF THE PHILIPPINES

G.R. No. 182438, 2 July 2014.

FACTS: Joey Umadac and Claire Bingayen were to marry on 29 March 2003 at the Sta. Rosa Catholic
Parish Church in Ilocos Norte. But on the day of the wedding, the church's officiating priest refused to
solemnize the marriage because of lack of a marriage license. The couple and the guests already
dressed for the wedding, they headed to an Aglipayan Church. The Aglipayan priest, herein petitioner
Rene Ronulo solemnized their marriage without the marriage license. Knowingly to Rene, he still
proceeded with the ceremony saying it was an act of “blessing” and was not tantamount to solemnization
of marriage - guilty. Rene Ronulo was charged of violating Article 352 of the RPC for performing an
illegal marriage ceremony.

ISSUE: Is the solemnization illegal?

Is his “blessing” the marriage mitigates the violation?

RULING:
1. Yes

Article 352 of the RPC penalizes an authorized solemnizing officer who shall perform or authorize
any illegal marriage ceremony. The elements of this crime are, 1) authority of the solemnizing
officer; and  2) his performance of an illegal marriage ceremony.

Ronulo admitted that he has the authority to solemnize a marriage. The second element is
present since the alleged "blessing" by Petitioner is tantamount to the performance of an illegal
marriage ceremony. Ronulo conducted the marriage ceremony despite knowledge that the
essential and formal requirements of marriage set by law were lacking. The marriage ceremony,
therefore, was illegal.

2. Considering that the solemnization was illegal and that considering the Ronulo pushed through
with the solemnization despite his knowledge of the lack of a marriage license, negates his
defense of “blessing” the marriage in good faith.