IWASAWA v GANGAN AUTHOR: PARIAN (Edited by: Ocampo, Miguel)

[G.R. No. 204169. September 11, 2013] NOTES: (if applicable)

TOPIC: Bigamous marriages, ENTRIES IN THE CIVIL
REGISTER,NCC 407-413, ROC, R108, RA9048, as
amended by RA10172
PONENTE: Villarama, Jr., J.

FACTS: (chronological order)

 1994: Respondent Felisa Gangan married Raymond Arambulo
 2002: Gangan introduced herself to petitioner Yasuo Iwasawa as single. Later that year, they got married
and moved to Japan.
 2009: Gangan got news that Arambulo died and she got depressed. Iwasawa inquired about her depression
and found out that she had a prior existing marriage.
 Iwasawa filed a declaration of nullity of his marriage with Gangan for being bigamous.
 He presented to the RTC: (1) certificate of marriage between Arambulo and Gangan; (2) certificate of
marriage between Iwasawa and Gangan; (3) death certificate of Arambulo.
 RTC dismissed the case for the evidence he presented is unreliable. He was a stranger to the documents.
 Iwasawa filed for certiorari.
ISSUE(S): WON the documents presented should be admitted as evidence of marriage
HELD: Yes. RTC decision set aside. Marriage of Iwasawa and Gangan declared null and void.

RATIO:
 The documents submitted are public documents. In effect, as per NCC 410: The books making up the civil register
and all documents relating thereto shall be considered public documents and shall be prima facie evidence of the
facts therein contained.
 As public documents, they are admissible in evidence even without further proof of their due execution and
genuineness.
 Therefore, the public documents are prima facie proof that Gangan had a prior existing marriage when she married
Iwasawa.
CASE LAW/ DOCTRINE:
Marriage certificates, being a public document, are prima facie evidence that such marriage is a fact.
DISSENTING/CONCURRING OPINION(S):