Title
Santos vs. Santos
Case
G.R. No. 214593
Decision Date
Jul 17, 2019
A marriage declared null due to psychological incapacity; compromise on property upheld, but marital validity not subject to agreement; extrinsic fraud claims insufficient.

Case Summary (G.R. No. 200465)

Trial Events and RTC Decision

The nullity case proceeded to trial. Leodegario presented witnesses including a clinical psychologist and himself. When it was Dana’s turn to present evidence, her counsel failed to appear despite notice. The RTC, by order dated February 26, 2009, declared Dana to have waived her right to present evidence and directed submission. On June 24, 2009 the RTC declared the marriage null and void for Dana’s psychological incapacity (Histrionic Personality Disorder). Dana received the decision August 26, 2009.

Post-Judgment Remedies at Trial Level

Dana filed a Notice of Appeal but later withdrew it and filed a petition for relief from judgment on October 19, 2009 alleging extrinsic fraud and mistake that prevented her from presenting evidence. The RTC denied the petition for relief (order dated February 17, 2010), and denied reconsideration (order dated April 22, 2010).

Appellate Proceedings and Compromise Agreement

Dana sought certiorari relief in the CA, which referred the parties to mediation. On June 6, 2011, the parties executed a compromise agreement providing for transfer of conjugal real property titles to their four children. The CA, on July 19, 2011, declared the case closed and terminated by virtue of the compromise agreement and ordered entry of judgment.

Subsequent Allegations of Non‑Compliance and Motions to Reopen

Dana later alleged noncompliance by Leodegario with the compromise (manifestation July 3, 2012; Motion to Reopen Aug 14, 2012). Leodegario manifested and later produced documentary proof — annotated transfer certificates of title, deeds of sale, and new titles — asserting compliance with the compromise.

CA Resolutions Denying Reopening and Reconsideration

The CA issued two resolutions: April 15, 2014 denying Dana’s Motion to Reopen for lack of merit, noting Leodegario’s manifest showing compliance and observing Dana had not shown her own compliance; and September 26, 2014 denying her Motion for Reconsideration/ to Submit Petition for Decision, holding the compromise concerned only property relations and that the RTC decision had already severed the marital ties, such that the compromise did not settle the validity of the marriage. Dana elevated the matter by a petition for review on certiorari to the Supreme Court on November 24, 2014.

Issues Presented to the Supreme Court

Dana framed three issues: (1) whether the CA resolutions terminating the case by reason of the compromise were erroneous as contrary to the State’s mandate to defend the sanctity of marriage (invoking Sections 1 and 2, Article XV of the Constitution); (2) whether the CA resolutions, which effectively upheld the RTC’s denial of her petition for relief, violated her right to due process; and (3) whether the CA erred in treating the RTC decision as final despite Dana’s petition for relief from judgment.

Governing Law and Procedural Framework

The substantive issues of marriage nullity are governed by the Family Code and relevant provisions of the New Civil Code. The procedural regulation specifically applicable to nullity cases is A.M. No. 02-11-10-SC, with the Rules of Court applying suppletorily. Because the decision was rendered in 2019, the 1987 Constitution is the constitutional basis referenced in the proceedings and in Dana’s constitutional argument.

Finality of Judgment and the Petition for Relief

The Court agreed with the CA and OSG that the RTC decision had attained finality in the ordinary sense, but emphasized that the filing of a petition for relief from judgment under Rule 38 (A.M. No. 02-11-10-SC sanctions the suppletory application of the Rules of Court) kept the proceedings alive in the sense that the petition seeks to set aside a final judgment. The Court distinguished finality of the underlying judgment from the appellate court’s duty when reviewing a denial of a petition for relief: the appellate court must determine whether the trial court committed grave abuse of discretion in denying the petition, which requires examining the grounds alleged (fraud, mistake, accident, excusable negligence) and, where appropriate, the merit of the petitioner’s cause or defense.

Compromise Judgments, Scope of Compromise, and Article 2035

The Court reiterated that a judgment upon compromise, once judicially approved, is immediately executory and has the force of a judgment. Nevertheless, Article 2035(2) of the New Civil Code prohibits compromises on the validity of a marriage. Applying these principles, the Court held that the CA erred insofar as it treated the compromise (which on its face addressed property relations) as terminating the entire nullity litigation including the validity of the marriage. The compromise in this case concerned property disposition and could not validly compromise the issue of marital validity; therefore the CA should not have dismissed the nullity suit on the ground that the compromise resolved it. The Court nonetheless recognized that the compromise as to property, absent vices of consent, remained binding and was properly executed and complied with by the parties.

Standard for Extrinsic Fraud, Counsel Negligence, and Application to Dana’s Claims

The Court reviewed the jurisprudential standard for extrinsic or collateral fraud — fraud that prevents a party from fully and fairly presenting a

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