Case Digest (G.R. No. 132955) Core Legal Reasoning Model
Facts:
This case involves petitioner Orlando Villanueva and private respondent Lilia Canalita-Villanueva, who got married on April 13, 1988, in Puerto Princesa, Palawan. On November 17, 1992, petitioner Orlando filed a petition for the annulment of his marriage on the grounds of duress, specifically alleging that threats of violence forced him to marry Lilia, who was reportedly already pregnant at the time. He denied impregnating her before the marriage, claimed he never cohabited with her, and asserted that he learned the child died at delivery on August 29, 1988. Lilia countered, arguing the marriage was entered into voluntarily, contending that Orlando stayed with her for almost a month post-marriage, wrote her letters, and knew about the pregnancy, which resulted in a prematurely born son. Lilia prayed for dismissal of the annulment petition and claimed moral and exemplary damages, attorney’s fees, and costs. The trial court dismissed the petition and ordered Orlando to pay damage
Case Digest (G.R. No. 132955) Expanded Legal Reasoning Model
Facts:
- Parties and Marriage
- Petitioner Orlando Villanueva and private respondent Lilia Canalita-Villanueva were married on April 13, 1988 in Puerto Princesa, Palawan.
- Subsequent to the marriage, petitioner filed a petition for annulment on November 17, 1992.
- Grounds and Contentions for Annulment
- Petitioner alleged that his consent to marriage was vitiated by threats of violence and duress, claiming he was forced to marry because private respondent was pregnant.
- He declared:
- He did not impregnate private respondent prior to marriage.
- He never cohabited with her after the marriage.
- He later learned private respondent’s child died during delivery on August 29, 1988.
- Private Respondent’s Answer and Counterclaim
- She argued that petitioner married her freely and voluntarily.
- Petitioner stayed with her almost a month after the marriage in Palawan.
- Petitioner wrote letters to her after returning to Manila, and she personally visited him.
- Petitioner knew of her pregnancy, which ended with a premature birth of their son.
- She prayed for dismissal of the petition and for moral and exemplary damages, attorney’s fees, and costs.
- Trial Court Decision (January 12, 1996)
- The Regional Trial Court dismissed the petition for annulment.
- Ordered petitioner to pay:
- Moral damages: ₱100,000.00
- Exemplary damages: ₱50,000.00
- Attorney’s fees: ₱20,000.00 plus costs.
- Court of Appeals Decision (January 26, 1998)
- Affirmed trial court’s dismissal of annulment petition.
- Reduced moral damages to ₱50,000.00 and exemplary damages to ₱25,000.00.
- Affirmed award of attorney’s fees and costs.
- Denied petitioner’s motion for reconsideration (March 5, 1998).
- Petitioner’s Appeal to the Supreme Court
- Assigned errors:
- Grave abuse of discretion by Court of Appeals for not granting annulment due to vitiated consent and absence of cohabitation.
- Error in awarding moral and exemplary damages and attorney’s fees without legal basis.
Issues:
- Whether the marriage may be annulled on the ground that petitioner’s consent was obtained by fraud, intimidation, duress, or undue influence.
- Whether petitioner should be held liable for moral and exemplary damages as well as attorney’s fees and costs.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)