Case Summary (G.R. No. 232189)
Factual Background
Alex Raul B. Blay filed a Petition for Declaration of Nullity of Marriage before the RTC, seeking nullity on grounds of psychological incapacity under Article 36 of the Family Code. Cynthia B. Bana filed an Answer with Compulsory Counterclaim on December 5, 2014. Thereafter, Blay filed a Motion to Withdraw his petition on March 11, 2015. Bana opposed that motion and, invoking Section 2, Rule 17 of the Rules of Court, manifested her desire that her counterclaim be declared remaining for independent adjudication in the same action.
Trial Court Proceedings
The RTC granted Blay's Motion to Withdraw in an Order dated May 29, 2015. The RTC declared Bana's counterclaim "as remaining for independent adjudication" and directed Blay to file an answer to the counterclaim within fifteen days. Blay moved for reconsideration, which the RTC denied by Order dated March 3, 2016. The RTC thus proceeded on the premise that the counterclaim survived within the same action despite dismissal of the petition.
Court of Appeals Proceedings
Blay elevated the matter to the Court of Appeals by filing a petition for certiorari, contending that the RTC erred in permitting the counterclaim to remain for adjudication in the same action. In its Decision dated February 23, 2017, the Court of Appeals dismissed the petition for lack of merit. The CA reasoned that under Section 2, Rule 17 of the Rules of Court, where a counterclaim has been pleaded prior to service of the plaintiff's motion for dismissal, "the dismissal shall be limited to the complaint," and therefore the counterclaim survived in the same action. A motion for reconsideration to the CA was denied in a Resolution dated June 6, 2017.
Issue
The dispositive legal question for the Supreme Court was whether the Court of Appeals erred in upholding the RTC Orders that declared Bana's counterclaim to remain for independent adjudication in the same action notwithstanding her failure to file the statutory manifestation within fifteen days from notice of the Motion to Withdraw.
Parties' Contentions
Blay argued that Section 2, Rule 17 of the Rules of Court requires a defendant who desires to have his counterclaim resolved in the same action to file a manifestation within fifteen days from notice of the plaintiff's motion to dismiss, and that Bana failed to comply with that requirement. Bana maintained that, because a counterclaim was pleaded before service of the motion to withdraw, the dismissal should be limited to the complaint and the counterclaim should automatically remain for adjudication in the same action.
Supreme Court Ruling
The Supreme Court granted the petition. The Court reversed and set aside the CA Decision dated February 23, 2017 and the CA Resolution dated June 6, 2017. The Supreme Court entered a new judgment solely granting Blay's Motion to Withdraw and ordered that the dismissal be without prejudice to the prosecution of Bana's counterclaim in a separate action.
Legal Basis and Reasoning
The Court analyzed Section 2, Rule 17 of the Rules of Court, emphasizing that the provision must be read in its entirety. The Court noted that the second sentence of the rule limits dismissal to the complaint where a counterclaim has been pleaded prior to service of the plaintiff's motion for dismissal. The Court further underscored the third sentence, which conditions the defendant's option to have the counterclaim resolved in the same action upon filing a manifestation within fifteen days from notice of the plaintiff's motion to dismiss. The Court explained that the fifteen-day period marks the point at which the dismissal of the complaint attains finality and thereby bars further proceedings in the same action unless the defendant timely manifests his preference to keep the counterclaim in that action. The Court rejected the CA's narrow reading that overlooked the third sentence and held that such a reading would render the manifestation requirement meaningless. Relying on principles of statutory construction, the Court required a ha
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Case Syllabus (G.R. No. 232189)
Parties and Procedural Posture
- ALEX RAUL B. BLAY was the petitioner who filed a Petition for Declaration of Nullity of Marriage before the RTC alleging psychological incapacity under Article 36 of the Family Code.
- CYNTHIA B. BANA was the respondent who filed an Answer with Compulsory Counterclaim in the same proceeding.
- The petitioner later filed a Motion to Withdraw his petition which the Regional Trial Court granted and subsequently the Court of Appeals affirmed.
- The petitioner sought relief from the Supreme Court by filing a petition for review on certiorari under Rule 45 challenging the CA rulings that allowed the counterclaim to remain for adjudication before the same trial court.
Key Factual Allegations
- The petition for declaration of nullity was filed before the RTC on September 17, 2014 and alleged psychological incapacity under Article 36 of the Family Code.
- The respondent filed her Answer with Compulsory Counterclaim on December 5, 2014.
- The petitioner filed a Motion to Withdraw dated March 11, 2015 seeking dismissal of his complaint at his instance.
- The respondent filed a comment/opposition invoking Section 2, Rule 17, Rules of Court and later filed a manifestation asserting her preference to have her counterclaim adjudicated in the same action.
Procedural History
- The RTC, in an Order dated May 29, 2015, granted the petitioner’s Motion to Withdraw and declared the respondent’s counterclaim “as remaining for independent adjudication.”
- The RTC gave the petitioner fifteen days to file an answer to the counterclaim and denied his motion for reconsideration in an Order dated March 3, 2016.
- The petitioner elevated the matter to the Court of Appeals by certiorari, which in a Decision dated February 23, 2017 dismissed the petition and affirmed the RTC Orders.
- The CA denied the petitioner’s motion for reconsideration in a Resolution dated June 6, 2017, prompting the present petition to the Supreme Court.
Issue
- The principal issue presented was whether the Court of Appeals erred in upholding the RTC Orders that declared the respondent’s counterclaim to remain for independent adjudication in the same action despite the petitioner's withdrawal and the respondent’s alleged failure to file a timely manifestation under Section 2, Rule 17, Rules of Court.
Statutory Framework
- Section 2, Rule 17, Rules of Court provides that when a counterclaim has been pleaded prior to service of the plaintiff’s motion for dismissal, the dismissal shall be limited to the complaint and shall be without prejudice to the defendant’s right to prosecute the counterclaim in a separate action unless th