Case Digest (G.R. No. 235498) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On May 3, 2012, Queenie Angel M. Relucio was born out of wedlock to petitioner Renalyn A. Masbate and respondent Ricky James Relucio in Legazpi City. The couple lived with Renalyn’s parents, Spouses Renato and Marlyn Masbate, until their de facto relationship ended in April 2015, when Renalyn moved to Manila for dentistry studies, allegedly leaving Queenie with Ricky James. On November 7, 2015, the maternal grandparents removed Queenie from her school and presented a Special Power of Attorney purportedly granting them full custody. In response, Ricky James filed a petition for habeas corpus and child custody (SP No. FC-15-239) before the Regional Trial Court (RTC), Branch 8, Legazpi City. After a brief hearing on December 3, 2015, the RTC issued an Order on December 4, 2015, invoking the second paragraph of Article 213 of the Family Code (tender-age presumption) and Article 176 (sole maternal authority over illegitimate child) to dismiss the petition and award custody to Renalyn... Case Digest (G.R. No. 235498) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- Queenie Angel M. Relucio was born on May 3, 2012 to Renalyn A. Masbate (mother) and Ricky James Relucio (father), who were cohabiting without marriage.
- In April 2015, the relationship ended; Renalyn left for Manila to study dentistry, leaving Queenie in Ricky James’s custody.
- Initiation of Habeas Corpus and Child Custody Proceeding
- On November 7, 2015, Renalyn’s parents purportedly took Queenie from school, presenting a Special Power of Attorney executed by Renalyn granting them custody.
- Ricky James filed a petition for habeas corpus and custody (SP No. FC-15-239) before the RTC of Legazpi City, Branch 8.
- Regional Trial Court (RTC) Disposition
- A hearing on December 3, 2015 was held without formal evidence presentation; Queenie was produced in court and Renalyn expressed desire to keep her.
- On December 4, 2015, the RTC granted custody to Renalyn, citing Article 213 of the Family Code (tender-age presumption).
- Ricky James’s motion for reconsideration was denied on January 7, 2016, the RTC reaffirming sole maternal authority under Article 176 and finding no proof of the mother’s unfitness.
- Court of Appeals (CA) Proceedings
- Ricky James appealed; on January 12, 2017 the CA set aside the RTC orders and remanded for trial to determine custody, affirming interim custody with Renalyn and granting Ricky James two days’ visitation weekly.
- On October 3, 2017, the CA denied petitioners’ motion for reconsideration and, upon Ricky James’s motion for clarification, granted him “limited and temporary custody” once a month for 24 hours, without reducing visitation rights.
- Supreme Court Petition
- Renalyn and her parents filed a petition for review on certiorari challenging the CA’s remand and the grant of temporary custody.
- Ricky James opposed, asserting timeliness and urging immediate execution of the CA resolution.
Issues:
- Whether the CA correctly remanded the case for trial to determine who should exercise custody over Queenie under the tender-age presumption of Article 213 of the Family Code.
- Whether the CA lawfully granted temporary custody to Ricky James in addition to his visitation rights.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)