G.R. No. L-27930 - Anaya vs. Palaroan

Procedural History
On December 4, 1953, Aurora A. Anaya and Fernando O. Palaroan were married.
On January 7, 1954, Fernando filed an annulment suit in the Court of First Instance of Manila (Civil Case No. 21589), alleging his consent was obtained by force and intimidation.
On September 23, 1959, the court dismissed Fernando’s complaint, upheld the validity of the marriage, and granted Aurora’s counterclaim for support.

New Action and Pleadings
During negotiations to settle the counterclaim judgment, Fernando disclosed to Aurora that he had had a premarital relationship with a close relative.
Aurora then filed a new annulment complaint in the Juvenile & Domestic Relations Court of Manila (Civil Case No. E-00431), alleging fraud under Article 85(4) of the Civil Code for non-disclosure of this premarital secret, and praying for annulment and moral damages.
Fernando’s answer denied the fraud allegations, denied any premarital relationship, and raised defenses of lack of cause of action and estoppel; he counterclaimed for malicious prosecution damages.
Aurora’s reply (answer to the counterclaim) alleged a separate fraud: that Fernando had feigned courtship solely to evade marrying his relative, secretly intended not to perform marital duties or cohabit, and in fact courted and lived with another woman, fathering children during the nine-year pendency of Civil Case No. 21589.

Lower Court Action and Appeal
The JDR Court set the case for trial on August 26, 1966, but upon reviewing the pleadings motu proprio found the fraud allegations legally insufficient under Articles 85 and 86 of the Civil Code.
The court required Aurora to show cause why the complaint should not be dismissed; finding her memorandum inadequate, it dismissed the complaint on October 7, 1966, and denied reconsideration.
Aurora appealed to the Supreme Court, contending that both the nondisclosure of the premarital relationship and her reply-allegations of secret intent constituted valid grounds for annulment.

Whether nondisclosure of a husband’s premarital relationship with another woman constitutes actionable fraud vitiating consent under Article 85(4) and Article 86 of the Civil Code.
Whether allegations of secret intent not to perform marital duties and simulated courtship, first raised in the reply, constitute a valid additional ground for annulment.
Whether any such secret-intent fraud claim is barred by the four-year prescriptive period for annulment actions.