Case Summary (G.R. No. 174803)

Background of the Case

• The petition for review challenges the Court of Appeals' Decision dated July 26, 2006.
• The case involves two consolidated civil cases: one filed by Marywin Albano Sales for the dissolution of the conjugal partnership and separation of properties, and another filed by Mayor Reynolan T. Sales for the declaration of nullity of their marriage.
• The Regional Trial Court (RTC) ruled on January 4, 2000, declaring the marriage void due to mutual psychological incapacity and ordering the dissolution of their conjugal partnership.

RTC's Initial Ruling

• The RTC's decision included directives for the liquidation and distribution of common properties and shared expenses for their child.
• Following the finality of the RTC decision, Marywin filed a motion for execution and proposed a partition of their assets, which was opposed by Reynolan.

Reynolan's Opposition and RTC Hearings

• Reynolan contested the motion, asserting that the RTC's decision lacked specificity regarding the properties and claimed that Marywin had no rightful share.
• The RTC scheduled hearings to address the claims, but several were postponed, and Marywin filed a reiterative motion for execution.

RTC's Approval of Partition

• On November 28, 2003, the RTC approved Marywin's proposed partition in Reynolan's absence, leading to Reynolan's subsequent motion for reconsideration.
• Reynolan argued that the RTC's approval preempted unresolved issues regarding property relations and alleged fraudulent activities by Marywin.

Court of Appeals' Decision

• The Court of Appeals ruled in favor of Reynolan, setting aside the RTC's orders and remanding the case for further hearings.
• The appellate court emphasized the importance of due process and the need for a hearing to address the factual issues raised by Reynolan.

Legal Issues Raised by the Parties

• Petitioner contended that the Court of Appeals exceeded its jurisdiction by entertaining the appeal and argued that due process was not violated.
• Respondent maintained that the RTC should not have granted the partition without a hearing, citing unresolved issues regarding property accounting and alleged misappropriation by Marywin.

Supreme Court's Ruling

• The Supreme Court affirmed the Court of Appeals' d...continue reading

Case Syllabus (G.R. No. 174803)

Case Citation

• Jurisprudence Reference: 610 Phil. 187
• Date: July 13, 2009
• G.R. No.: 174803
• Division: Second Division

Parties Involved

• Petitioner: Marywin Albano-Sales
• Respondents: Mayor Reynolan T. Sales and Court of Appeals

Background of the Case

• The controversy arises from two civil cases:
  • Civil Case No. Q-94-19236: Filed by Marywin against Reynolan for the dissolution of conjugal partnership and separation of properties.
  • Civil Case No. Q-97-32303: Filed by Reynolan for the declaration of nullity of their marriage.
• Both cases were consolidated for joint trial.

Trial Court Decision

• Date of Judgment: January 4, 2000
• Ruling: The RTC declared the marriage void ab initio due to mutual psychological incapacity.
• Order:
  • Dissolution of the conjugal partnership.
  • Liquidation, partition, and distribution of common properties within 60 days.
  • Shared responsibility for the support and education of their child, Maindryann Sales.

Subsequent Motions and Orders

• Motion for Execution: Filed by Marywin on June 16, 2003, to partition assets, listing specific properties.
• Reynolan's Opposition: He contended that the RTC’s decision lacked specificity regarding asset distribution and claimed Marywin had no claim to the properties.
• RTC Orders:
  • September 3, 2003: Set a hearing for evidence reception regarding claims.
  • November 28, 2003: Approved Marywin's reiterative...continue reading