Case Digest (G.R. No. 174803)
Facts:
The case involves Marywin Albano-Sales as the petitioner and Mayor Reynolan T. Sales as the respondent. The events leading to this case began with two civil cases filed in the Regional Trial Court (RTC) of Quezon City. The first, Civil Case No. Q-94-19236, was initiated by Marywin against her husband, Reynolan, seeking the dissolution of their conjugal partnership and separation of properties. The second, Civil Case No. Q-97-32303, was filed by Reynolan for the declaration of nullity of their marriage. These cases were consolidated and jointly tried. On January 4, 2000, the RTC ruled that the marriage was void due to mutual psychological incapacity, ordering the dissolution of their conjugal partnership and directing the parties to liquidate and distribute their common property.
After the RTC's decision became final on June 16, 2003, Marywin filed a motion for execution and a manifestation listing their assets for partition. Reynolan opposed this motion, arguing that th...
Case Digest (G.R. No. 174803)
Facts:
Marriage and Legal Proceedings:
- Marywin Albano-Sales and Mayor Reynolan T. Sales were married but later filed separate cases: Marywin sought the dissolution of their conjugal partnership and separation of properties (Civil Case No. Q-94-19236), while Reynolan filed for the declaration of nullity of their marriage (Civil Case No. Q-97-32303). The cases were consolidated.
- On January 4, 2000, the Regional Trial Court (RTC) declared their marriage void ab initio due to mutual psychological incapacity under Article 36 of the Family Code. The court also ordered the dissolution of their conjugal partnership and the liquidation, partition, and distribution of their common properties.
Post-Judgment Proceedings:
- After the decision became final, Marywin filed a motion for execution and a manifestation listing her assets with Reynolan for partition. Reynolan opposed, arguing that the properties were fruits of his sole industry and that Marywin had no share. He also claimed that Marywin had appropriated rentals and sold properties without his consent, violating Article 147 of the Family Code.
- The RTC set the case for hearing to resolve these issues, but the hearing was postponed multiple times. Marywin filed a reiterative motion for execution, proposing a partition of their townhouse units. The RTC granted the motion in the absence of Reynolan and his counsel.
Reynolan’s Motion for Reconsideration:
- Reynolan moved to reconsider the RTC’s order, arguing that the court preempted the issues he raised, such as the fraudulent sale of properties and non-accounting of rentals. He also contended that their property relations should not be governed by co-ownership rules since they did not live together as husband and wife.
- The RTC denied Reynolan’s motion, ruling that reception of evidence was no longer necessary since the parties were legally married and had a child together, proving their connubial relations were more than transient.
Appeal to the Court of Appeals:
- Reynolan appealed to the Court of Appeals, which set aside the RTC’s orders and remanded the case for further hearing. The appellate court held that the RTC’s recall of its previous order for further reception of evidence violated Reynolan’s constitutional right to property and due process.
Issue:
- Did the Court of Appeals err in entertaining Reynolan’s appeal from an order granting the issuance of a writ of execution?
- Was Reynolan deprived of his right to due process when the RTC approved the partition of their common properties without prior hearing?
- Did the Court of Appeals err in holding that Marywin manipulated the issuance of the RTC’s order dated November 28, 2003?
Ruling:
The Supreme Court affirmed the Court of Appeals’ decision, holding that:
- The Court of Appeals did not err in entertaining Reynolan’s appeal because the RTC’s orders dated November 28, 2003, and April 12, 2004, were final orders that disposed of the issues concerning the partition of the parties’ common properties. These orders were appealable under Section 1, Rule 41 of the Rules of Court.
- Reynolan was deprived of his right to due process when the RTC granted Marywin’s reiterative motion without prior hearing. The RTC’s previous order calling for the reception of evidence had to be observed to address Reynolan’s allegations regarding the collection of rentals, sale of properties, and misappropriation of proceeds.
- The Court of Appeals correctly held that the RTC’s recall of its previous order for further reception of evidence violated Reynolan’s constitutional rights. The case was remanded to the lower court for further reception of evidence in accordance with the RTC’s Order dated September 3, 2003.
Ratio:
- (Unlock)