G.R. No. 132524 - Suntay vs. Cojuangco-Suntay

On July 9, 1958, Emilio Aguinaldo Suntay and Isabel Cojuangco-Suntay were married in the Portuguese Colony of Macao.
The couple had three children: Margarita Guadalupe, Isabel Aguinaldo, and Emilio Aguinaldo, all bearing the surname Cojuangco-Suntay.
The marriage later became contentious as issues arose regarding the mental capacity of one party and subsequent legal actions.

In 1962, Isabel filed a criminal case against Emilio, which was followed by Emilio’s complaint for legal separation filed before the Court of First Instance (CFI).
The CFI, in its decision rendered on October 3, 1967, declared the marriage “null and void” in its dispositive portion.
The annulment was primarily based on allegations that one party suffered from a mental disorder (schizophrenia) which had manifested as early as 1955 and persisted despite later treatment, thus affecting her capacity for understanding right from wrong.

The trial court relied on expert testimony, particularly from a neuro-psychiatrist, to establish the mental condition and incapacity of the plaintiff.
The legal basis for the annulment was anchored on Article 85 of the Civil Code, which permits annulment on grounds of unsound mind existing at the time of the marriage.
An important distinction was noted between a marriage being “null and void” and one being “voidable,” with the latter being valid until annulled, thereby preserving certain legal consequences.

Cristina Aguinaldo-Suntay, the decedent and Isabel’s paternal grandmother, died on June 4, 1990, intestate.
On October 26, 1995, Isabel filed a petition before the Regional Trial Court (RTC) for Letters of Administration of her grandmother’s estate, relying on her status as a legitimate grandchild with succession by representation.
Federico C. Suntay, petitioner in the present case, opposed the appointment of Isabel as administratrix, asserting his status as the surviving spouse of the decedent and contending that he was better positioned to protect the estate’s interests.

On September 22, 1997, petitioner Federico C. Suntay moved to dismiss the special proceeding case against Isabel’s petition on the ground that, under Article 992 of the Civil Code, an illegitimate child (as alleged due to the annulment of her parents’ marriage) cannot succeed by representation.
The trial court, however, denied the motion to dismiss, mandating that the special proceeding continue, given that the case was not adversarial in the conventional sense and required resolution for purposes including tax and escheat implications.
Subsequent motions, including a motion for reconsideration, were denied, leading the petitioner to file a petition for certiorari under Rule 65, alleging grave abuse of discretion in the handling of the motions.

Petitioner argued that the declaratory phrase “null and void” in the dispositive portion of the earlier decision should categorically render the marriage void ab initio, thereby affecting the legitimacy of the children born of the marriage.
Respondent Isabel countered that the marriage, being voidable until annulled, nevertheless produced all its civil effects before the decree and that the status of the children (conceived and born prior to the decree) remains legitimate under Article 89 of the Civil Code.
There was also a dispute as to whether the dispositive portion or the body of the earlier decision should control in interpreting the legal effect of the annulment, and whether petitioner’s motion to dismiss was timely and properly filed under the Rules of Civil Procedure.

Whether the dispositive portion of the Court of First Instance decision, which declares the marriage “null and void,” is controlling over the body of the decision that also discusses annulment.
Whether any ambiguity between the rationale (ratio decidendi) and the fallo (dispositive portion) affects the legal consequences regarding the legitimacy of children born from that marriage.

Whether petitioner Federico C. Suntay’s motion to dismiss (filed on September 22, 1997) was timely, given that it was filed after the filing of the opposition (analogous to an answer in an ordinary civil action).
Whether the filing of such motion, almost two years after the opposition by respondent, should be considered dilatory and procedurally improper.

Whether, based on the prior annulment proceedings and relevant legal provisions, respondent Isabel’s status as a legitimate grandchild entitles her to be appointed as administratrix of her grandmother’s estate through succession by representation.
Whether the petitioner’s argument on the illegitimacy of the child (due to the annulled marriage) holds legal merit under Articles 85 and 89 of the Civil Code.