G.R. No. 210929 - Republic vs. Orcelino-Villanueva

The case involves Edna Orcelino-Villanueva, the respondent, who sought a judicial declaration that her absent husband, Romeo L. Villanueva, be declared presumptively dead pursuant to Article 41 of the Family Code.
Edna and Romeo were married on December 21, 1978, in Iligan City.
In 1993, while Edna was working as a domestic helper in Singapore and Romeo as a mechanic in Bukidnon, Edna received news from her children that Romeo had left their conjugal home without explanation or contact, raising doubts about his whereabouts and, eventually, his status.

Following the news of Romeo’s disappearance, Edna took a leave of absence and returned to the Philippines to search for him.

Her inquiries included questioning her parents-in-law and common friends in Iligan City and Valencia City.
She also went to his birthplace in Escalante, Negros Oriental, to inquire from his relatives.

Despite these efforts—primarily consisting of her personal assertions and unauthenticated inquiries—Edna filed a petition on August 6, 2009, with the Regional Trial Court (RTC) for a declaration of presumptive death under Article 41 of the Family Code.

The RTC, Branch 10 in Malaybalay City, granted Edna’s petition based on her “well‑founded belief” that Romeo was dead, despite her being the sole witness and her evidence being largely uncorroborated.
On August 13, 2010, the Office of the Solicitor General (OSG), representing the Republic of the Philippines, filed a petition for certiorari under Rule 65 before the Court of Appeals (CA), arguing that the RTC had abused its discretion and disregarded established jurisprudence.
On October 18, 2013, the CA dismissed the petition for certiorari, holding that the RTC had acted within its jurisdiction and citing Article 247 of the Family Code which confers immediate finality to the RTC’s judgment.
A subsequent motion for reconsideration filed on November 20, 2013, was denied on January 8, 2014.

The OSG then elevated the matter to the Supreme Court via a petition for review on certiorari under Rule 45 of the Rules of Court.
Central to the dispute was whether the lower courts had incorrectly accepted Edna’s evidence and findings as sufficient to establish a “well‑founded belief” in her husband’s death, in light of prevailing jurisprudence on the matter.

Whether or not the Court of Appeals erred in affirming the RTC decision despite the conclusion reached by the RTC being contrary to established jurisprudence regarding the requirement of a well‑founded belief under Article 41 of the Family Code.
Whether or not the Court of Appeals was correct in characterizing the grounds raised by the petitioner (OSG) as mere errors of judgment, particularly with respect to the inadequacy of Edna’s efforts and evidence to prove her belief that Romeo was dead.