Case Digest (G.R. No. 132955)
Facts:
Orlando Villanueva v. Hon. Court of Appeals and Lilia Canalita‑Villanueva, G.R. No. 132955, October 27, 2006, Supreme Court First Division, Ynares‑Santiago, J., writing for the Court.
Petitioner Orlando Villanueva and private respondent Lilia Canalita‑Villanueva were married on April 13, 1988 in Puerto Princesa, Palawan. On November 17, 1992 Orlando filed a petition for annulment of marriage in the Regional Trial Court (RTC), Branch 172, Valenzuela (Civil Case No. 3997‑V‑92), alleging that his consent had been vitiated by threats, intimidation and duress that forced him to marry Lilia while she was pregnant; he also alleged non‑cohabitation and asserted that he did not impregnate Lilia.
In her answer, with a compulsory counterclaim, Lilia denied coercion and fraud, averred that Orlando freely and voluntarily married her, that they cohabited briefly in Palawan and maintained contact thereafter (including letters and visits), and that she indeed delivered a premature child who died; she prayed for dismissal of the petition and for moral and exemplary damages, attorney’s fees and costs.
On January 12, 1996 the RTC dismissed Orlando’s petition and ordered him to pay Lilia moral damages of P100,000, exemplary damages of P50,000, attorney’s fees of P20,000 and costs of suit. On January 26, 1998 the Court of Appeals in CA‑G.R. CV No. 51832 affirmed the dismissal and the award of attorney’s fees and costs but reduced moral and exemplary damages to P50,000 and P25,000, respectively; its March 5, 1998 resolution denied Orlando’s motion for reconsideration.
Orlando filed a petition for review under Rule 45 of the Rules of Court assailing the Court of Appeals’ decision and resolution. The record shows competing factual proofs: Orlando relied on alleged harassing phone calls, visits by unknown men, and the presence of a man he called “Ka Celso” to establish duress and on alleged inconsistencies about the date of the fetal death to sustain a fraud claim; he also contended there was no cohabitation. The trial court and the Court of Appeals found, however, that Orlando freely consented to the marriage, that he admitted a sexual relationship with Lilia, that documentary and testimonial evidence supported Lilia’s account, and that Orlando’s long delay in filing (over four years) and the weakness of his evidence undermined hi...(Pro-only)
Issues:
- May the marriage between Orlando Villanueva and Lilia Canalita‑Villanueva be annulled on the ground that petitioner’s consent was vitiated by fraud, intimidation, duress or lack of cohabitation?
- Is private respondent entitled to moral and exemplary damages and at...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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