Case Digest (G.R. No. 169627)
Facts:
The case involves Rosemarie Salma Aragoncillo-Molok (petitioner) and Sity Aisa Barangai Molok (respondent). The respondent and Col. Agakhan M. Molok, both residents of Matina, Davao City, were married on June 29, 1992, in a ceremony officiated by Judge Virginia Hofllena-Europa at the Municipal Trial Courts in Cities, Ecoland, Matina, Davao City. Their marriage was duly registered at the Local Civil Registrar of Davao City on July 3, 1992. Col. Agakhan Molok, a member of the Philippine Army, passed away on November 20, 2003, in General Santos City. When the respondent sought to claim her late husband's death benefits from the Philippine Army, she discovered that another individual, Rosemarie Salma Aragoncillo-Molok, was also claiming to be his wife. The petitioner asserted her claim based on a Certificate of Marriage executed on May 20, 1999, in Taguig, Metro Manila, which was purportedly solemnized by Imam Ustadz Moha-imen Ulama under Muslim rites at the Manila Golden Mos...
Case Digest (G.R. No. 169627)
Facts:
Marriage of Respondent and Agakhan Molok
- Sity Aisa Barangai Molok (respondent) and Col. Agakhan M. Molok were married on June 29, 1992, in Davao City. The marriage was solemnized by Judge Virginia Hofllena-Europa and registered at the Local Civil Registrar of Davao City under Registry No. 1495 on July 3, 1992.
Death of Agakhan Molok
- Agakhan Molok, a member of the Philippine Army, died on November 20, 2003, in General Santos City.
Discovery of Second Marriage
- When respondent attempted to claim her late husband's death benefits, she discovered that Rosemarie Salma Aragoncillo-Molok (petitioner) had also claimed to be Agakhan Molok's wife. Petitioner presented a Certificate of Marriage dated May 20, 1999, purportedly solemnized under Muslim rites at the Manila Golden Mosque and Cultural Center. This marriage was registered at the Shari'a District Court Muslim Civil Registrar of Zamboanga City under Registry No. 25901 on June 14, 2004.
Investigation into the Second Marriage
- Respondent found that:
- The Manila Golden Mosque and Cultural Center had no record of the second marriage (per Certification dated August 14, 2004).
- The solemnizing officer, Ustadz Moha-imen Ulama, denied solemnizing the marriage (per Affidavit dated May 4, 2004).
Legal Action by Respondent
- Respondent filed a verified petition on October 17, 2004, before the Third Shari'a District Court of Zamboanga City, seeking the cancellation of the registration of the second marriage. The petition was later amended to include the Shari'a District Court Registrar and OIC Civil Registrar as respondents.
Trial Court Proceedings
The trial court issued an Order on January 24, 2005, setting the hearing for March 28, 2005, and requiring publication and posting of notices. Petitioner filed a Manifestation on March 16, 2005, opposing the petition and requesting a copy of the petition and its exhibits to file a responsive pleading. The trial court did not act on this Manifestation.
During the March 28, 2005 hearing, only respondent and her counsel appeared. The trial court rendered a Decision on June 28, 2005, declaring the second marriage null and void and ordering its cancellation from the registry.
Motion for Reconsideration
- Petitioner filed a motion for reconsideration, which was set for hearing on September 1, 2005. However, no hearing was held due to a non-working Muslim holiday. The trial court denied the motion by Order dated July 25, 2005, without addressing the due process issue raised by petitioner.
Issue:
- Whether petitioner was denied her right to due process when the trial court failed to furnish her with a copy of the petition and its annexes, preventing her from filing a formal opposition.
- Whether the trial court erred in rendering its decision solely based on respondent's petition without considering petitioner's opposition.
Ruling:
The Supreme Court GRANTED the petition. The Decision and Order of the Third Shari'a District Court dated June 28, 2005, and July 25, 2005, respectively, were REVERSED and SET ASIDE. The case was REMANDED to the trial court for further proceedings.
Ratio:
- Denial of Due Process: The trial court violated petitioner's constitutional right to due process by failing to furnish her with a copy of the petition and its annexes, despite her explicit request. This prevented her from filing a formal opposition and participating meaningfully in the proceedings.
- Adversarial Nature of Proceedings: Under Rule 108, the proceedings are adversarial, requiring both parties to be given an opportunity to present their case. The trial court's failure to act on petitioner's Manifestation and provide her with the necessary documents deprived her of this opportunity.
- Remand for Further Proceedings: The Supreme Court emphasized the importance of due process and remanded the case to ensure that petitioner is given a fair chance to present her defense.