Case Digest (G.R. No. 232189)
Facts:
The case involves Alex Raul B. Blay as the petitioner and Cynthia B. BaAa as the respondent. On September 17, 2014, Blay filed a Petition for Declaration of Nullity of Marriage before the Regional Trial Court (RTC) of Pasay City, seeking to have his marriage to BaAa declared null and void based on his psychological incapacity as per Article 36 of the Family Code. In response, BaAa filed her Answer with a Compulsory Counterclaim on December 5, 2014. However, as the case progressed, Blay lost interest in pursuing the petition and subsequently filed a Motion to Withdraw his petition. In her opposition to this motion, BaAa invoked Section 2, Rule 17 of the Rules of Court, requesting that her counterclaims be declared as remaining for the court's independent adjudication. Blay countered that BaAa's counterclaims were barred from being prosecuted in the same action due to her failure to file a manifestation within the required fifteen (15) days from the notice of his Motion...
Case Digest (G.R. No. 232189)
Facts:
Filing of the Petition for Declaration of Nullity of Marriage
On September 17, 2014, petitioner Alex Raul B. Blay filed a Petition for Declaration of Nullity of Marriage before the Regional Trial Court (RTC) of Pasay City, Branch 109. He sought to have his marriage to respondent Cynthia B. BaAa declared null and void under Article 36 of the Family Code, citing psychological incapacity as the ground.
Respondent’s Answer and Counterclaim
Respondent filed her Answer with Compulsory Counterclaim on December 5, 2014. She opposed the petition and raised counterclaims against the petitioner.
Petitioner’s Motion to Withdraw
Subsequently, petitioner lost interest in pursuing the case and filed a Motion to Withdraw his petition on March 11, 2015. Respondent opposed this motion, invoking Section 2, Rule 17 of the Rules of Court, and requested that her counterclaims remain for independent adjudication.
Timeliness of Respondent’s Manifestation
Petitioner argued that respondent failed to file a manifestation within 15 days from receiving the Motion to Withdraw, as required under Section 2, Rule 17. Respondent received the motion on March 11, 2015, but only filed the manifestation on March 30, 2015, which was beyond the 15-day period.
Issue:
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Ruling:
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Ratio:
Section 2, Rule 17 of the Rules of Court governs the dismissal of a complaint at the plaintiff’s instance. It provides that if a counterclaim has been pleaded before the plaintiff’s motion for dismissal is served, the dismissal shall be limited to the complaint. However, the defendant must manifest within 15 days from notice of the motion if they wish to prosecute the counterclaim in the same action. Otherwise, the counterclaim must be pursued in a separate action.
The Court emphasized that the 15-day period is crucial. Failure to file the required manifestation within this period triggers the finality of the dismissal of the complaint, barring further proceedings in the same action. This ensures procedural efficiency and prevents undue delay.
The CA erred by narrowly interpreting Section 2, Rule 17 and ignoring the third sentence, which requires the defendant to manifest their preference within 15 days. The Court stressed that statutory construction requires that all parts of a provision be harmonized to give effect to the law’s intent.
The Court rejected the CA’s reasoning that the counterclaim automatically remains for adjudication. Such an interpretation would render the 15-day manifestation requirement meaningless. The Court agreed with petitioner’s argument that if the counterclaim automatically remained, there would be no need for the defendant to manifest their preference.
Consequently, the RTC should have only granted petitioner’s Motion to Withdraw and dismissed the petition without prejudice to respondent prosecuting her counterclaim in a separate action.
Conclusion:
The Supreme Court reversed the CA’s Decision and Resolution. It ruled that respondent’s counterclaim could not remain for independent adjudication in the same case due to her failure to file the required manifestation within the 15-day period. The dismissal of petitioner’s petition was upheld, but respondent’s counterclaim must be pursued in a separate action.