Case Summary (G.R. No. 245617)
Applicable Law
The substantive laws governing this case primarily include the Family Code of the Philippines, specifically Article 36 regarding psychological incapacity, and provisions of the New Civil Code pertaining to compromise agreements.
Administrative History
The initial petition for nullity of marriage was filed on September 11, 2003, leading to a decision by the RTC on June 24, 2009, declaring the marriage null and void. Following this, Dana attempted to appeal but later withdrew in favor of a Petition for Relief from Judgment, which was subsequently denied. The CA upheld this denial and noted the parties had entered a compromise agreement regarding property relations, dismissing the validity of Dana's claims around the marriage itself.
Summary of Court Resolutions
The CA rendered two significant resolutions: on April 15, 2014, it denied Dana's Motion to Reopen her Petition for Relief, stating she failed to show compliance with the compromise agreement. On September 26, 2014, the CA rejected her Motion for Reconsideration, affirming that the compromise agreement did not address marital validity but rather property disputes. Dana then sought a review by the Supreme Court arguing violations of her due process rights and the sanctity of marriage.
Issues Raised by Dana
Dana contended that the CA's resolutions improperly settled the issue of her marriage's validity through a compromise agreement, which is prohibited under Article 2035 of the Civil Code, maintaining that a marriage's validity cannot be compromised. She further alleged due process violations, arguing that her inability to present evidence was unjustly disregarded.
Ruling of the Supreme Court
The Supreme Court found Dana's petition to have no merit, affirming the finality of the RTC decision due to Dana's procedural missteps, particularly the failure to file a proper appeal or sought remedy prior to the compromise. The Court reiterated that entering into a compromise concerning property does not equate to a compromise on marital validity.
Finality of the RTC Decision
The Court upheld that the RTC's ruling declaring the marriage void had attained finality upon Dana’s withdrawal of the appeal and subsequent actions. Although the CA's dismissal based on the compromise agreement contained an error regarding the scope of issues, the Supreme Court determined that this error did not alter the binding nature of the agreements made regarding property.
Conclusion
The Supreme Court ultimately supported the CA’s resolutions, affirming the closure of
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Case Overview
- This case involves a petition for review on certiorari filed by Dana S. Santos against Leodegario R. Santos, challenging the resolutions of the Court of Appeals dated April 15, 2014, and September 26, 2014.
- The core issue pertains to the validity of a compromise agreement related to the nullity of their marriage and the denial of Dana's petition for relief from judgment.
Background of the Case
- Dana and Leodegario Santos met in 1982, and after years of cohabitation, they married on December 3, 1987.
- The couple had four children together, but their marriage deteriorated over time, characterized by arguments and suspicions of infidelity.
- In 2001, they filed for the dissolution of their conjugal partnership, which was granted, and subsequently, Leodegario filed a petition for the declaration of absolute nullity of their marriage on September 11, 2003, citing Dana's psychological incapacity.
Proceedings in the Regional Trial Court
- The RTC of Antipolo City issued a decision on June 24, 2009, declaring the marriage null and void based on Dana's Histrionic Personality Disorder.
- Dana was served with the decision on August 26, 2009, and although she initially filed a notice of appeal, she later withdrew it and filed a petition for relief from judgment on October 19, 2009, alleging extrinsic fraud and mistake.
Court of Appeals’ Resolutions
- The CA denied Dana's petition for relief, stating there were insufficient allegations of f