Case Summary (G.R. No. 159521)
Nature of the Case
This case is a petition for review on certiorari seeking to reverse a Decision and Resolution by the Court of Appeals dated April 2, 2003, and August 8, 2003, respectively. Erminda's complaint alleged that Francisco was psychologically incapacitated and abusive, whereas Francisco contended that it was Erminda who was psychologically incapable. The trial court found in favor of Erminda, declaring the marriage void ab initio.
Trial Findings
The trial court, upon reviewing evidence, found that Francisco's behavior, including physical abuse and psychological inflictions on Erminda, constituted psychological incapacity. The trial court determined that his condition, referred to as satyriasis, impaired his ability to fulfill the essential obligations of marriage. The ruling led to the annulment of their marriage and the division of their properties.
Decision of the Trial Court
The trial court's decision included a comprehensive judgment stating that the marriage is null and void, awarded custody of the children to Erminda, and mandated monthly support payments from Francisco. The court also ordered the dissolution of the conjugal partnership, providing specific valuations for properties acquired during the marriage.
Appeal and Court of Appeals’ Decision
Dissatisfied with the property division, Francisco appealed the decision to the Court of Appeals. He conceded the annulment but contested the manner in which the properties were divided. The Appellate Court upheld the trial court's decision, affirming that the property should be divided based on Article 147 of the Family Code, which governs the property relations of parties involved in a void marriage or living together without the benefit of marriage.
Article 147 of the Family Code
Under Article 147, when a couple who are capacitated to marry live together without marriage or under a void marriage, their properties acquired through their joint efforts are presumed to be owned in equal shares. The article specifies that even if one party did not directly participate in property acquisition, their contributions to the household can still reflect a joint effort in property ownership.
Assessment of Contributions to the Business
Despite Francisco’s claims to exclusive ownership of the pizza business and properties, evidence indicated that Erminda played a significant managerial role in the business operations. Francisco acknowledged Erminda’s contributions, and testimonies demonstrated that Erminda actively participated in the business, managing daily operations without pay. This factor contributed heavily to the trial court's findings reg
...continue readingCase Syllabus (G.R. No. 159521)
Case Overview
- The case involves a petition for review on certiorari filed by Francisco L. Gonzales (petitioner) against Erminda F. Gonzales (respondent) challenging the decisions of the Court of Appeals.
- The petition seeks to reverse the Decision dated April 2, 2003, and Resolution dated August 8, 2003, which affirmed the trial court's findings regarding the annulment of their marriage and the division of properties.
Background of the Case
- Francisco and Erminda began cohabitating in March 1977 and formalized their marriage on February 4, 1979.
- They had four children: Carlo Manuel, Maria Andres, Maria Angelica, and Marco Manuel.
- On October 29, 1992, Erminda filed for annulment, citing Francisco's psychological incapacity due to abusive behavior and infidelity.
Allegations and Counterclaims
Erminda's Claims:
- Francisco was psychologically incapacitated to fulfill marital obligations, exhibiting abusive behavior and infidelity.
- She contributed significantly to their pizza business, managing operations and generating income.
Francisco's Defense:
- Francisco countered that Erminda was the one psychologically incapacitated.
- He claimed sole ownership of the properties acquired during their marriage and denied Erminda's management role in the business.
Trial Court Findings
- The trial court found overwhelming evid