G.R. No. 182438, July 2, 2014
RENE RONULO, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioner Fr. Rene Ronulo, an Aglipayan priest, was charged with violating Article 352 of the Revised Penal Code (performing an illegal marriage ceremony). The evidence showed that on March 29, 2003, Joey Umadac and Claire Bingayen, who failed to secure a marriage license and were refused solemnization by a Catholic priest, proceeded to the Aglipayan Church. Petitioner conducted a ceremony for them despite being informed they had no marriage license. The ceremony included the bride walking down the aisle, an exchange of rings, a kiss, the signing of a document, and instructions for sponsors to sign a marriage contract. Witness Florida Umadac (groom’s mother) testified she heard the couple declare they take each other as husband and wife. Petitioner admitted conducting a ceremony but denied it was a solemnization, claiming it was merely a “blessing.” The Municipal Trial Court found him guilty and imposed a ₱200.00 fine under Section 44 of Act No. 3613 (the Marriage Law). The Regional Trial Court and the Court of Appeals affirmed the conviction.

ISSUE

Whether the petitioner’s act of “blessing” the couple constitutes the performance of an “illegal marriage ceremony” punishable under Article 352 of the Revised Penal Code.

RULING

The Supreme Court DENIED the petition and AFFIRMED the conviction. The Court held that the prosecution proved the elements of the crime under Article 352 of the Revised Penal Code: (1) the petitioner was an authorized solemnizing officer, which he admitted, and (2) he performed an illegal marriage ceremony. Applying Article 6 of the Family Code (derived from Article 55 of the Civil Code and Section 3 of the Marriage Law), a marriage ceremony requires only: (a) the personal appearance of the contracting parties before the solemnizing officer, and (b) their declaration in the presence of at least two witnesses of legal age that they take each other as husband and wife. No prescribed form or religious rite is required. The Court found both requirements were met based on the petitioner’s admission, witness testimonies (particularly Florida Umadac’s account of the declaration), and the surrounding circumstances (exchange of rings, signing of document). The Court rejected the petitioner’s arguments: (1) The principle of separation of church and state is preserved by the law’s lack of a prescribed form for the ceremony, but the State can define the legal requisites of marriage; (2) Criminal intent is not an element of the crime; (3) The non-filing of a case against the couple under Article 350 of the RPC does not preclude prosecution of the solemnizing officer under Article 352; (4) The penalty is properly based on Section 44 of the Marriage Law, which penalizes violations of its provisions. The “blessing” conducted without a marriage license was an illegal marriage ceremony.