G.R. No. 132696 - People vs. Navarro

Initial Petition for Declaration of Nullity on Ground of Psychological Incapacity

On October 24, 1995, Oscar P. Mallion filed a petition with the Regional Trial Court (RTC), Branch 29, San Pablo City, seeking the declaration of nullity of his marriage to Editha Alcantara under Article 36 of the Family Code on the ground of respondent’s alleged psychological incapacity.
The case was docketed as Civil Case No. SP 4341-95.
After trial on the merits, the RTC denied the petition by decision dated November 11, 1997, finding that petitioner failed to produce preponderant evidence to grant the relief sought.
Petitioner appealed to the Court of Appeals (CA), but the appeal was dismissed on June 11, 1998 due to non-payment of docket and other lawful fees.
The decision became final and executory.

Subsequent Petition for Declaration of Nullity on Ground of Lack of Marriage License

On July 12, 1999, petitioner filed a second petition with the same RTC for declaration of nullity of marriage citing that the marriage was celebrated without a valid marriage license.
Respondent filed a motion to dismiss alleging res judicata and forum shopping on August 13, 1999.
The RTC granted the motion to dismiss on October 8, 1999, dismissing the case based on forum shopping and multiplicity of suits.
Petitioner’s motion for reconsideration was denied on January 21, 2000.

Petitioner argued that the two cases involved different causes of action since the first was based on psychological incapacity and the second on absence of marriage license.
He contended that there was no violation of rules against res judicata, forum shopping, or splitting of cause of action.
Respondent countered that both cases involved the same issue—the validity of marriage—and the same relief, thus constituting forum shopping and multiplicity of suits.

Whether a final judgment denying a petition for declaration of nullity on the ground of psychological incapacity bars a subsequent petition for declaration of nullity on the ground of lack of marriage license.
Whether the filing of a second petition based on a different ground but seeking the same relief constitutes res judicata and forum shopping.