Case Summary (G.R. No. 249953)
Key Dates
- Marriage: August 14, 2004
- Birth of first child (Mejan Dia): December 1, 2001
- Filing of annulment petition: March 15, 2011
- RTC Decision annulling marriage: November 16, 2017
- CA Resolutions dismissing appeal: February 26, 2019; September 20, 2019
- Supreme Court Decision: June 23, 2021
Applicable Law
- 1987 Philippine Constitution
- Family Code of the Philippines (Articles 45 and 46)
- Rules of Court (Rule 13 on proof of filing; Rule 22 on computation of time; Rule 45 on certiorari; Rule 50 on grounds for dismissal of appeal)
Facts
- Melvin and Janufi met in 1996, separated in 2000, reconciled in March 2001.
- Janufi became pregnant in April 2001; Melvin doubted paternity until she assured him he was the only partner.
- Their daughter Mejan Dia was born in December 2001; they married in August 2004. A second child, Javen Mel, was born in October 2004.
- Marital disputes frequently focused on Mejan Dia’s paternity. A 2010 DNA test showed 0.0% probability of Melvin’s paternity.
- Janufi sent text admissions in January and March 2011 acknowledging a one-time indiscretion while intoxicated.
- Melvin filed for annulment on the ground of fraud (concealment of non-paternity) under Article 45(3) in relation to Article 46(2) of the Family Code.
Procedural Background
- RTC granted annulment, finding Janufi fraudulently concealed that Mejan Dia was by another man.
- The Republic, through OSG, appealed to the CA. The CA dismissed for failure to timely file the appellate brief under Rule 50, Section 1(e). A motion for reconsideration was denied.
- OSG filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court, challenging both the CA’s procedural ruling and the RTC’s substantive annulment. Melvin filed a comment supporting the CA.
Issues for Review
- Whether the CA erred in dismissing the Republic’s appeal for failure to file the appellate brief within a reasonable period.
- Whether the RTC erred in annulling the marriage on the ground of fraud under Article 45(3) in relation to Article 46(2) of the Family Code.
Supreme Court’s Procedural Ruling
- Rule 13, Section 3: pleadings filed by registered mail are deemed filed on the mailing date if supported by registry receipt and affidavit.
- OSG submitted registry numbers and a post office request but lacked the required registry receipts and affidavit.
- In the interest of substantial justice, the Court deemed the motion for extension timely (filed January 30, 2019) and recognized that the appellate brief was received by the CA on May 2, 2019—timely under Rule 22 when May 1 fell on a holiday.
- The CA’s dismissal under Rule 50, Section 1(e) was reversed, with a reminder that procedural rules serve justice and should not defeat substantive rights.
Supreme Court’s Merits Analysis on Annulment
- Article 45(3) permits annulment for consent obtained by fraud; Article 46(2) limits such fraud to concealment by the wife of pregnancy by another man at the time of marriage.
- Mejan Dia was almost three years old when the parties married; Janufi was not pregnant at the time. Thu
Case Syllabus (G.R. No. 249953)
Factual Background
- Melvin T. Villacorta and Janufi Sol P. Villacorta met in March 1996 at Southwestern University, Cebu City; their relationship ended in 2000.
- After months apart, Janufi reconciled with Melvin in March 2001, denying any involvement with another man, which led to their reunion.
- In April 2001, Janufi revealed she was one month pregnant; despite Melvin’s doubts, she assured him he was the sole partner.
- On December 1, 2001, Janufi gave birth to Mejan Dia; the couple began cohabiting and later married on August 14, 2004.
- Their second child, Javen Mel, was born on October 18, 2004. Disputes over Mejan Dia’s paternity recurred throughout their marriage.
- A 2010 dinner quarrel prompted Melvin to undergo a DNA test, which proved with 0.0% probability that he fathered Mejan Dia.
- Janufi’s text messages in January and March 2011 admitted to a one-time infidelity while drunk and “white lies,” with no intent to deceive.
- On March 15, 2011, Melvin filed a petition for annulment of marriage on the ground of fraud.
Regional Trial Court Decision
- Branch 22, Cebu City RTC rendered its November 16, 2017 Decision annulling the marriage for fraud under Article 45(3) and Article 46(2) of the Family Code.
- The RTC concluded that Janufi concealed that Mejan Dia was sired by another man and that Melvin would not have married her had he known.
Court of Appeals Rulings
- In CA-G.R. CV. No. 06988, the CA dismissed the Republic’s appeal in its February 26, 2019 Resolution for failure to timely file the appellate brief per Rule 50, Section 1(e).
- The OSG