G.R. No. 172198 - De Castro vs. De Castro, Jr.

Petitioner Ma. Lourdes C. De Castro and private respondent Crispino De Castro, Jr. were married on January 1, 1971.
In 1996, private respondent filed a petition for the declaration of nullity of the marriage before the RTC of Manila.
Private respondent alleged that:

He was impulsive and reckless in his youth and, while still in school, impregnated petitioner.
They got married to avoid exposing their families to embarrassment.
Their marital relationship deteriorated due to his immaturity, frequent quarrels, abandonment, and involvement with other women.
Counseling efforts to save the marriage were unsuccessful.
In 1992, he permanently left the family home to live with another woman, with whom he had three children.

Petitioner failed to file her Answer in the original petition, leading to the case being set for hearing.
Private respondent testified and presented expert evidence through psychiatrist Dr. Cecilia Albaran.
On June 22, 1998, the RTC rendered a decision annulling the marriage based on the finding that both parties were psychologically incapacitated to enter into marriage, which is a valid ground under the Family Code.
The RTC ordered the cancellation of the marriage registration in the Registry of Marriages.

On August 3, 1998, petitioner filed a motion seeking a new trial or reconsideration of the annulment decision, alleging that she was misled and prevented from fully participating in the case.
The trial court granted the omnibus motion in an order dated December 11, 1998, which required petitioner to submit a question-and-answer form affidavit to constitute her direct testimony.
Multiple hearings were scheduled relating to:

Petitioner’s application for support pendente lite and urgent motion for judicial deposit of separation benefits.
Private respondent’s motion for judicial approval of an alleged voluntary agreement on the dissolution of the conjugal partnership and partition of conjugal properties.

Initial scheduling commenced on July 17, 2002, with the hearing reset to August 21, 2002 for petitioner’s direct testimony.
Subsequent reschedulings occurred as follows:

October 2, 2002 – Rescheduled on September 30, 2002 at the instance of private respondent due to his trip to Europe.
November 13, 2002 – Moved by private respondent because his counsel was out of the country.
December 11, 2002 – Cancelled upon petitioner’s counsel’s motion on account of petitioner’s urgent business commitment related to her volunteer work for Bantay Bata.
February 6, 2003 – Reset of the hearing, which was later moved again on February 20, 2003 by petitioner’s counsel.
March 27, 2003 – Hearing cancelled due to the presiding judge’s official leave.
April 10, 2003 – Hearing reset by agreement of the parties.
May 8, 2003 – Reset owing to the absence of both parties’ counsel.
July 25, 2003 – Rescheduled again when petitioner’s counsel moved due to petitioner being in the U.S.
August 20, 2003 – Final scheduled hearing where petitioner’s counsel again sought cancellation because petitioner was still abroad and her witness Dr. Maria Cynthia Ramos-Leynes was also out of the country.

On July 25, 2003, the trial court, despite motions for another postponement, warned that another postponement would result in the case being submitted for decision.
During the August 20, 2003 hearing, the court dismissed further postponement requests and deemed that private respondent had waived her right to present additional evidence, ordering her to file an offer of exhibits within fifteen days.
Petitioner’s subsequent motion to reconsider the August 20, 2003 order was filed but later denied on December 12, 2003, affirming that petitioner had ample opportunity to present her evidence and that her repeated postponements were self-induced.

Petitioner filed a petition for certiorari under Rule 65 seeking to annul the orders dated August 20, 2003 and December 12, 2003 on the ground of grave abuse of discretion.
The Court of Appeals dismissed the petition, ruling that:

The postponements were, in part, due to petitioner’s own actions and filed on the day of the hearings.
Adequate warning and opportunity had been extended to her to timely file motions and representations.
Certiorari was not the proper remedy for interlocutory orders and that the proper appeal remedy remained available in case of an eventual adverse judgment.

Whether the trial court abused its discretion in denying petitioner’s motion for postponement and subsequently her motion for reconsideration of the orders issued on August 20, 2003, and December 12, 2003.
Whether petitioner’s failure to appear on the scheduled hearing dates, leading to the waiver of her right to present further evidence, amounted to a violation of her due process rights and the state policy on marriage as a social institution.
Whether the orders resetting the hearings and ultimately deeming petitioner’s absence as a waiver of her right to submit evidence were justified given the numerous reschedulings and postponements.
Whether certiorari is the proper remedy against interlocutory orders that set the stage for a final judgment in the case.
How the conduct of the parties, in terms of timely filing postponement motions or representations, impacted the trial court’s decisions on evidentiary presentation and procedural fairness.