G.R. No. L-31600 - Prudential Bank and Trust Co. vs. Community Builders Co., Inc.

Dana S. Santos and Leodegario R. Santos first met in 1982 at a wake through a common friend and developed a romantic relationship.
The couple began cohabiting, which produced two children prior to their marriage.
Their business ventures prospered and they eventually married on December 3, 1987, before a Catholic priest, with two additional children born after the marriage.
Over time, their relationship deteriorated, marked by frequent heated arguments and suspicions of infidelity.
In 2001, they jointly petitioned for the dissolution of their conjugal partnership, which was subsequently granted.

On September 11, 2003, Leodegario filed a petition for declaration of absolute nullity of the marriage (Civil Case No. 03-6954) on the ground of psychological incapacity, focusing on an alleged disorder in Dana.
Dana filed an Answer on April 2, 2004, alleging that Leodegario’s petition was an attempt to marry his paramour and have a child with her.
The trial proceeded on the merits:

Leodegario presented evidence including a clinical psychologist, a former employee of their joint business, and his own testimony.
Dana’s counsel failed to appear when it was her turn to present evidence, despite notice.

On February 26, 2009, the trial court issued an order declaring Dana’s waiver of the right to present evidence, directing Leodegario to submit a memorandum before the case was deemed submitted.
On June 24, 2009, the trial court rendered its Decision declaring the marriage null and void on the ground of psychological incapacity, specifically holding that Dana suffered from grave, incurable, and juridically antecedent Histrionic Personality Disorder.
Dana received the decision on August 26, 2009, filed a Notice of Appeal on September 4, 2009, and later withdrew the appeal to file a Petition for Relief from Judgment on October 19, 2009, alleging extrinsic fraud and mistake.

Leodegario filed a comment on Dana’s petition for relief, and the trial court denied her petition for relief from judgment on February 17, 2010; her subsequent motion for reconsideration was also denied on April 22, 2010.
Dana elevated the issue by filing a petition for certiorari with the Court of Appeals, which led to further pleadings.
The CA, via a Resolution dated February 7, 2011, sent her petition for mediation.
On June 6, 2011, under CA mediation, Dana and Leodegario entered into a compromise agreement regarding the transfer of their conjugal real properties in favor of their four common children.
Subsequent filings by Dana alleged non-compliance by Leodegario with the compromise, prompting her to file:

A Motion to Reopen and/or Reinstate the Petition on August 14, 2012.
A Motion for Reconsideration and/or to Submit Petition for Decision (with Plea to Preserve Marital Union).

The first Resolution on April 15, 2014 denied Dana’s Motion to Reopen, noting her failure to show compliance with the compromise agreement.
The second Resolution on September 26, 2014 dismissed her Motion for Reconsideration, holding that the compromise agreement, which pertained exclusively to their property relations, effectively terminated the suit regarding the validity of the marriage.

Dana subsequently filed the present petition for review on certiorari before the Supreme Court on November 24, 2014.

Whether the decision of the RTC declaring the marriage null and void attained finality even though Dana filed a petition for relief from judgment.
Whether the trial court’s denial of Dana’s petition for relief from judgment constitutes a grave abuse of discretion, thereby meriting the reopening of the case.

Whether the compromise agreement between Dana and Leodegario, approved by the CA and concerning their property relations vis-à-vis their children, unlawfully compromised the issue of the validity of their marriage.
Whether the CA erred in treating the compromise agreement as settling the marital status issue, in contravention of Article 2035 of the New Civil Code which prohibits compromise on the validity of marriage.

Whether Dana’s right to due process was violated by her inability to present evidence at trial, owing to her counsel’s allegedly negligent or nonchalant conduct.
Whether the alleged extrinsic fraud committed by her previous counsel in failing to apprise her of the hearings could justify the relief sought by Dana.