Case Summary (G.R. No. 172198)
Facts of the Case
In 1996, Crispino De Castro, Jr. sought to annul his marriage with Ma. Lourdes C. De Castro, claiming psychological incapacity which inhibited both parties from fulfilling the obligations of marriage. His allegations included emotional immaturity and infidelity. The RTC, after reviewing testimonies from both parties and an expert witness, declared the marriage null and void on June 22, 1998, citing sufficient evidence to support the claims of psychological incapacity.
Motion for Reconsideration and Subsequent Hearings
On August 3, 1998, Ma. Lourdes filed a Motion for Leave to file an Omnibus Motion seeking a new trial or reconsideration, asserting she had been misled into not participating in the annulment proceedings. The trial court granted her motion, leading to submissions of testimonies and further hearings. As various hearings were postponed due to the absence of the parties and their witnesses, a crucial hearing scheduled for August 20, 2003 was marked by the petitioner's non-appearance, which was subsequently deemed a waiver of her right to present further evidence.
Orders of the Trial Court
The trial court issued an order on August 20, 2003, declaring that the petitioner had waived her right to present evidence due to her absence. This was followed by a motion for reconsideration from Ma. Lourdes, which the court denied on December 12, 2003. The court emphasized the numerous opportunities afforded to her to present her case and the pattern of postponements requested primarily by her counsel, which contributed to the delays in proceedings.
Appeal to the Court of Appeals
Ma. Lourdes C. De Castro sought redress from the Court of Appeals through a petition for certiorari under Rule 65, contending that the RTC had exhibited grave abuse of discretion in its orders. The Court of Appeals dismissed her petition, concluding that the trial court acted reasonably within its discretion. The court highlighted how the petitioner’s conduct and repeated requests for postponements did not reflect serious intent to proceed with the case, thereby justifying the actions of the trial court.
Conclusion of the Supreme Court
Upon reviewing the case, the Supreme Court affirmed the decision of the Court of
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Case Background
- The case involves a petition for review on certiorari by Ma. Lourdes C. De Castro against Crispino De Castro, Jr., the Office of the City Prosecutor for Manila, and the Office of the Solicitor General.
- It originates from the Court of Appeals' Decision dated April 4, 2006, in CA-G.R. SP No. 81856.
- The core issue pertains to the Orders issued by Acting Judge Marvic Balisi-Umali of the Regional Trial Court (RTC) of Manila regarding the declaration of nullity of marriage.
Parties Involved
- Petitioner: Ma. Lourdes C. De Castro, who seeks to contest the annulment of her marriage.
- Private Respondent: Crispino De Castro, Jr., who filed the initial annulment petition.
- Respondents: Office of the City Prosecutor for Manila and the Office of the Solicitor General, involved in the legal proceedings.
Marriage and Annulment Proceedings
- Ma. Lourdes and Crispino were married on January 1, 1971.
- In 1996, Crispino filed a petition for annulment, citing psychological incapacity as the ground.
- He claimed impulsiveness and immaturity led to the marriage's failure, including instances of abandonment and infidelity.
Initial Ruling
- The RTC annulled the marriage on June 22, 1998, citing that both parties were psychologically incapacitated.
- The decision directed the cancellation of the marriage from the Registry of Marriages.
Petitioner’s Motion for Reconsideration
- On August 3,