G.R. No. L-15939 - Puig vs. Penaflorida

On September 17, 2014, petitioner Alex Raul B. Blay filed a Petition for Declaration of Nullity of Marriage before the RTC of Pasay City, Branch 109, alleging respondent Cynthia B. BaAa’s psychological incapacity under Article 36 of the Family Code.
On December 5, 2014, respondent filed her Answer with Compulsory Counterclaim.

On March 11, 2015, petitioner filed a Motion to Withdraw his nullity petition, signaling loss of interest in the case.
On March 26, 2015, respondent opposed the withdrawal, invoking Section 2, Rule 17 of the Rules of Court and seeking independent adjudication of her counterclaim.
Petitioner replied on April 29, 2015, arguing respondent’s manifestation to pursue her counterclaim in the same action was filed beyond the 15-day period prescribed by Section 2, Rule 17.

In an Order dated May 29, 2015, the RTC granted the Motion to Withdraw and declared respondent’s counterclaim “remaining for independent adjudication,” giving petitioner 15 days to answer it.
The RTC denied petitioner’s motion for reconsideration on March 3, 2016.

On February 23, 2017, the CA dismissed petitioner’s certiorari petition for lack of merit, upholding the RTC’s application of Section 2, Rule 17 and its declaration on the counterclaim.
The CA denied reconsideration on June 6, 2017, prompting this petition before the Supreme Court.

Whether the Court of Appeals erred in affirming the RTC Orders that allowed respondent’s compulsory counterclaim to remain for independent adjudication despite respondent’s failure to manifest within 15 days from notice of petitioner’s Motion to Withdraw, as required by Section 2, Rule 17 of the Rules of Court.