Case Digest (G.R. No. 186400)
Facts:
The case involves a petition for review on certiorari filed by Cynthia S. Bolos (petitioner) against Danilo T. Bolos (respondent). The events leading to this case began on July 10, 2003, when Cynthia filed a petition for the declaration of nullity of her marriage to Danilo under Article 36 of the Family Code, which was docketed as JDRC No. 6211. The marriage was solemnized on February 14, 1980, prior to the enactment of the Family Code on August 3, 1988. After a trial on the merits, the Regional Trial Court (RTC) of Pasig City, Branch 69, issued a decision on August 2, 2006, declaring the marriage null and void ab initio due to psychological incapacity of both parties. Danilo received a copy of this decision on August 25, 2006, and subsequently filed a Notice of Appeal on September 11, 2006. However, the RTC denied due course to the appeal on September 19, 2006, citing Danilo's failure to file a motion for reconsideration as required by Section 20 of the Rule on Declarati...
Case Digest (G.R. No. 186400)
Facts:
Marriage and Petition for Nullity
- Cynthia S. Bolos (petitioner) and Danilo T. Bolos (respondent) were married on February 14, 1980.
- On July 10, 2003, Cynthia filed a petition for the declaration of nullity of their marriage under Article 36 of the Family Code, citing psychological incapacity on the part of both parties. The case was docketed as JDRC No. 6211.
RTC Decision
- After trial, the Regional Trial Court (RTC) of Pasig City, Branch 69, granted the petition on August 2, 2006, declaring the marriage null and void ab initio due to psychological incapacity on both sides.
- Danilo received the decision on August 25, 2006, and filed a Notice of Appeal on September 11, 2006.
Denial of Appeal
- The RTC denied Danilo's appeal on September 19, 2006, for failing to file a motion for reconsideration or new trial, as required under Section 20 of A.M. No. 02-11-10-SC (Rule on Declaration of Absolute Nullity of Void Marriages and Annulment of Voidable Marriages).
- Danilo's motion for reconsideration was also denied on November 23, 2006.
- On January 16, 2007, the RTC declared its decision final and executory and granted Cynthia's Motion for Entry of Judgment.
CA Proceedings
- Danilo filed a petition for certiorari under Rule 65 with the Court of Appeals (CA), challenging the RTC's orders.
- The CA reversed the RTC's orders, ruling that A.M. No. 02-11-10-SC did not apply to marriages solemnized before the Family Code took effect (August 3, 1988). The CA relied on the Supreme Court's ruling in Enrico v. Heirs of Sps. Medinaceli.
- Cynthia's motion for reconsideration was denied by the CA on February 11, 2009, as the reglementary period for filing such a motion is non-extendible.
Supreme Court Petition
- Cynthia filed a petition for review on certiorari under Rule 45, arguing that A.M. No. 02-11-10-SC should apply to marriages solemnized before the Family Code's effectivity. She also contended that the CA erred in denying her motion for reconsideration.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Statutory Construction
- When the law is clear and unambiguous, it must be applied as written. The plain-meaning rule (verba legis) applies, and there is no need for interpretation. A.M. No. 02-11-10-SC is explicit in its scope and applies only to marriages under the Family Code.
Finality of Judgments
- The reglementary period for filing a motion for reconsideration is non-extendible. Failure to comply with this rule results in the finality of the judgment, and the appellate court loses jurisdiction to entertain further appeals.
Importance of Marriage as a Social Institution
- The Court reiterated the constitutional policy of protecting marriage as an inviolable social institution. The State has a vested interest in preserving the sanctity of marriage, and courts must ensure that parties are given every opportunity to uphold this institution.
Right to Appeal
- While the right to appeal is not a natural right, it is an essential part of the judicial system. Courts must proceed with caution to ensure that parties are not deprived of this right due to procedural technicalities.