Case Digest (G.R. No. 210487) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Reyes v. Elquiero (G.R. No. 210487, September 2, 2020), petitioner Melysinda D. Reyes, the biological aunt and actual custodian of the minor Irish Reyes Elquiero, assails the Court of Appeals’ April 26, 2012 Decision and December 12, 2013 Resolution in CA-G.R. SP No. 115366. Respondent Maria Salome R. Elquiero, Irish’s adoptive grandmother, filed a petition for a writ of habeas corpus with the Court of Appeals on March 26, 2010, alleging that Reyes unlawfully withheld Irish’s custody following the death of Irish’s adoptive father, Rex Elquiero, in 2009. The appellate court issued a writ returnable to the Regional Trial Court (RTC) of San Pablo City, Branch 30, which thereafter set mandatory pre-trial orders requiring submission of pre-trial briefs and presentation of the minor. Salome’s motion for reconsideration was denied on July 9, 2010. While the habeas corpus case proceeded, Salome also filed a guardianship petition in RTC-San Pablo City (Sp. Proc. Case No. SP-1768(09)) Case Digest (G.R. No. 210487) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Relationships
- Petitioner Melysinda D. Reyes (Melysinda) is the biological aunt of minor Irish Elquiero (Irish).
- Irish is the biological daughter of Melysinda’s brother and the legally adopted daughter of the late Rex R. Elquiero (Rex). Rex was the son of respondent Maria Salome R. Elquiero (Salome).
- Upon Rex’s death in February 2009, both Melysinda and Salome claimed custody of Irish.
- Habeas Corpus Proceedings (CA-G.R. SP No. 113286 → RTC San Pablo City)
- March 26, 2010: Salome filed a petition for writ of habeas corpus with the Court of Appeals (CA), alleging that Melysinda unlawfully withheld custody of Irish.
- March 31, 2010: CA issued the writ returnable to RTC Branch 30, San Pablo City and directed production of Irish.
- April 8, 2010: RTC hearings; RTC temporarily vested custody of Irish with Melysinda.
- April 12, 2010: Melysinda filed Opposition, challenging Salome’s personality to sue, alleging forum shopping and lack of genuine interest in Irish’s welfare.
- April 16, 2010 & July 9, 2010: RTC ordered submission of pre-trial briefs; Salome’s motion for reconsideration was denied.
- Salome elevated the April 16 and July 9 orders to the CA (docketed CA-G.R. SP No. 115366) and sought injunctive relief.
- Muntinlupa Custody Proceedings (RTC Branch 207 Muntinlupa → CA-G.R. CV No. 97013)
- June 15, 2010: Salome filed a separate petition for custody of Irish before RTC Muntinlupa, alleging entitlement as grandmother of the adoptive father.
- August 13, 2010: Melysinda answered, asserting lack of legal relationship between Salome and Irish, established custody bond, and accused Salome of forum shopping.
- January 11, 2011: RTC Muntinlupa granted Melysinda’s motion to dismiss for lack of cause—no legal relationship and forum shopping.
- April 12, 2011: RTC denied Salome’s motion for reconsideration.
- September 25, 2012: CA 16th Division denied Salome’s appeal, affirmed dismissal, found Salome and counsel guilty of multiple acts of forum shopping, and imposed show-cause requirement.
- Conflicting CA Rulings on Habeas Corpus Case
- CA 9th Division (April 26, 2012 Decision; December 12, 2013 Resolution):
- Treated the habeas corpus petition strictly under Rule 102 as a summary proceeding ancillary to custody.
- Held that the RTC erred in mandating pre-trial briefs, since habeas corpus is summary.
- Exonerated Salome from forum shopping, limiting the HC petition to legality of detention only.
- CA 16th Division (in Muntinlupa case): Held the habeas corpus case, guardianship case, and custody case involved identical parties, issues, and reliefs—constituting forum shopping.
- Supreme Court Petition and Issues Raised
- Petition for Review on Certiorari under Rule 45 assailed the CA 9th Division’s April 26, 2012 Decision and December 12, 2013 Resolution.
- Raised three principal issues:
- Grave abuse of discretion by RTC in ordering pre-trial.
- Salome’s alleged non-violation of the forum-shopping prohibition.
- Salome’s asserted lack of cause of action for custody of Irish.
Issues:
- Whether the Regional Trial Court, Branch 30, San Pablo City gravely abused its discretion in issuing the April 16, 2010 and July 9, 2010 orders requiring pre-trial pleadings in the habeas corpus proceeding.
- Whether Salome is guilty of forum shopping by filing successive and overlapping petitions (habeas corpus, guardianship, and custody) for the same essential relief.
- Whether Salome lacks a valid cause of action to seek custody of Irish, given the limits of adoption law and substitute parental authority under the Family Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)