Case Summary (G.R. No. 262727-28)
Background of the Case
Belinda and David Lim were married on June 27, 1971, and did not have a prenuptial agreement outlining the management of their property relations. The couple had two children who are now of legal age and residing in the United States. On November 24, 2015, David filed a petition in the RTC for the nullification of his marriage to Belinda, claiming psychological incapacity under Article 36 of the Family Code. The estimated value of their conjugal assets was initially cited as PHP 15,350,000 but was later contested by Belinda, who claimed the value was significantly higher, around PHP 186,830,000.
RTC Proceedings
Throughout the subsequent RTC proceedings, numerous motions were filed by both parties, including motions to amend petitions and motions for special orders regarding the sale of properties. David acknowledged a lack of knowledge about the total value of conjugal assets owing to his lack of access to titles and information on purchases made with conjugal funds. This led to David amending his original petition multiple times, ultimately resulting in the filing of a Third Amended Petition that listed the estimated value of conjugal assets as PHP 284,311,155.
Dispute Over Property Characterization
Belinda filed motions requesting court-authorized sales of certain properties, which she asserted were her paraphernal assets. David opposed these motions, arguing that the characterization of properties as paraphernal necessitated thorough determination and should not be presumed based solely on prior statements or judicial admissions made in court.
Court of Appeals Ruling
The Court of Appeals (CA) affirmed the RTC's decisions, holding that the RTC did not exhibit grave abuse of discretion when it allowed David to file a Third Amended Petition and denied Belinda’s Second Motion for Special Order. The CA emphasized that the RTC's discretion to permit amendments served the interests of justice by allowing the trial court to effectively resolve the real issues between the parties without delays caused by procedural technicalities.
Arguments Presented
Belinda argued that the CA erred, claiming the RTC's rulings violated procedural rules regarding the amendment of petitions and deprived her of the opportunity to be heard. She asserted that David's repeated amendments exhibited inexcusable delay and that properties that were not listed under the Amended Petitions should be deemed paraphernal.
David countered that he was not privy to the complete inventory of their conjoined assets due to Belinda having control over the documentation and purchasing decisions. He highlighted the presumption in law that properties acquired during marriage are considered conjugal unless validly proven as exclusive.
Legal Analysis
The Supreme Court analyzed the procedural rules involved, particularly Rule 10, Sect
...continue readingCase Syllabus (G.R. No. 262727-28)
Background and Procedural History
- Maria Claudia Belinda Candano-Lim (Belinda) and David Lim (David) married in 1971 without any property relations agreement.
- They had two adult children residing in the United States.
- In November 2015, David filed a petition for declaration of nullity of marriage under Article 36 of the Family Code alleging Belinda's psychological incapacity.
- David initially undervalued conjugal assets at PHP 15,350,000; Belinda claimed it was around PHP 186,830,000.
- David amended his petition twice to reflect increasing estimated conjugal asset values ultimately stating PHP 284,311,155.00 in a Third Amended Petition.
- Belinda filed motions to dismiss, for support, and for authorization to sell certain properties she claimed paraphernal.
- The RTC allowed David to amend petition multiple times and denied Belinda's motions to sell properties, ruling that the nature of properties (conjugal or paraphernal) required trial determination.
- Belinda filed a Rule 65 Petition for certiorari with the Court of Appeals which was denied.
- The Supreme Court took cognizance of the Petition for Review on Certiorari.
Issue
- Whether the Court of Appeals erred in finding that the Regional Trial Court did not commit grave abuse of discretion when it:
- Allowed David to file the Third Amended Petition without a prior written motion for leave of court.
- Denied Belinda's Second Motion for Special Order to sell several properties without David’s consent.
Relevant Law and Procedural Rules
- Article 36 of the Family Code provides psychological incapacity as ground for nullity of marriage.
- Rule 10, Sections 2 and 3 of the 1997 Rules of Court governs amendments to pleadings:
- Amendments as a matter of right allowed before responsive pleading is served.
- Substantial amendments after responsive pleading require leave of court by a motion filed in court with notice and opportunity to be heard.
- Rule 15, Sectio