Rosario wanted to go to Japan. A friend introduced her to a Japanese national named Yoshio Morimoto and suggested an arrangement that, according to Rosario, would help her obtain a Japanese visa. The plan was simple. They would simulate a marriage.

Rosario claimed that she and Yoshio met at Manila City Hall, where they signed a blank marriage certificate. She was assured that no marriage would actually take place and that the document would never be registered. It was the first and last time she ever saw Yoshio.

Years later, Rosario went to the Philippine Statistics Authority to obtain a Certificate of No Marriage. She received the shock of her life. According to government records, she was already married.

The records showed that she and Yoshio had supposedly been married in San Juan City before a minister and under a specific marriage license. Rosario insisted that none of it had happened.

She immediately filed a petition asking the courts to declare the marriage void. To support her petition, Rosario presented remarkable evidence. The local civil registrar certified that no marriage license had ever been issued to the parties.

Even more significantly, the Philippine Statistics Authority later admitted that it had mistakenly certified that a marriage had been solemnized between Rosario and Yoshio. The supposed marriage license could not be found because, according to the official records, it never existed.

Despite this, both the Regional Trial Court and the Court of Appeals dismissed Rosario’s petition. They were reluctant to declare the marriage void, emphasizing the law’s policy of protecting the institution of marriage.

Were the lower courts correct?

No, they were not. According to the Supreme Court, marriage is a special contract that requires genuine consent. Consent does not simply mean signing a document. It means that both parties truly intend to become husband and wife.

Here, Rosario herself admitted that the supposed marriage was merely a scheme to facilitate her visa application. There was never any intention to establish a real marital relationship. The Court held that such an admission was actually entitled to great weight because it was an admission against interest—Rosario was effectively confessing her own participation in a fraudulent scheme that could expose her to criminal liability.

The Supreme Court also found another fatal defect. The evidence showed that no marriage license had ever been issued to the parties.

Under the Family Code, the absence of a required marriage license renders the marriage void from the beginning, unless one of the statutory exceptions applies. None of those exceptions existed in this case.

The Court likewise emphasized that there had never been a genuine marriage ceremony. The supposed marriage was nothing more than a fabricated arrangement intended to create the appearance of a legal marriage for immigration purposes.

The Court warned that to recognize such a sham as valid would do greater harm to the institution of marriage than declaring it void. Courts should not become instruments for validating marriages that were never intended to exist in the first place.

Accordingly, the Supreme Court declared the supposed marriage between Rosario and Yoshio null and void from the beginning. The Court held that the parties never truly consented to become husband and wife, no valid marriage license had been issued, and the alleged marriage was merely a simulation used to obtain immigration benefits.

Ado-an-Morimoto v. Morimoto. G.R. No. 247576, March 15, 2021