Case Digest (G.R. No. 112019) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Santos vs. Court of Appeals and Bedia-Santos (G.R. No. 112019, January 4, 1995), petitioner Leouel Santos, then a First Lieutenant of the Philippine Army, met private respondent Julia Rosario Bedia-Santos in Iloilo City and contracted civil and church marriages on September 20, 1986, before MTC Judge Cornelio G. Lazaro. The young couple initially lived with Julia’s parents at the J. Bedia Compound in La Paz, Iloilo City, and on July 18, 1987, Julia gave birth to their son, Leouel Jr. Marital life soon soured due to domestic quarrels and in-law interference. On May 18, 1988, Julia left for the United States to work as a nurse; she first called Leouel by long-distance on January 1, 1989, promising to return in July 1989 but never did. When Leouel underwent AFP training in the U.S. from April 10 to August 25, 1990, he tried unsuccessfully to locate Julia. Failing to secure her return, he filed a “Complaint for Voiding of Marriage Under Article 36 of the Family Code” (Civil Case Case Digest (G.R. No. 112019) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Marriage
- Petitioner: Leouel Santos, then First Lieutenant in the Philippine Army.
- Respondent: Julia Rosario Bedia-Santos.
- Wedding and Domestic Life
- Civil and church ceremonies held on 20 September 1986 before MC Trial Court Judge Cornelio G. Lazaro in Iloilo City.
- Couple resided with Julia’s parents at the J. Bedia Compound, La Paz, Iloilo City.
- Birth of their son, Leouel Santos, Jr., on 18 July 1987.
- Marital Breakdown and Judicial Proceedings
- Julia departed for the United States on 18 May 1988 to work as a nurse, promising to return in July 1989 but never doing so.
- Petitioner’s 1990 U.S. training stint (10 April–25 August 1990) failed to produce any contact with Julia.
- Petitioner filed Civil Case No. 9814 (RTC Negros Oriental, Br. 30) on 1 January 1991 for nullity of marriage under Art. 36, Family Code.
- Summons by publication; Julia answered, denied allegations, then ceased participation and evidence submission.
- RTC dismissed for lack of merit on 6 November 1991; Court of Appeals affirmed.
- Petitioner elevated the case to the Supreme Court via petition for review on certiorari.
Issues:
- Whether private respondent was psychologically incapacitated at the time of the celebration of marriage to comply with its essential marital obligations under Article 36 of the Family Code.
- Whether the petition was procedurally infirm for non-compliance with Circular No. 28-91’s certification against forum shopping.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)