Title
Villanueva vs. Court of Appeals
Case
G.R. No. 132955
Decision Date
Oct 27, 2006
Orlando sought annulment, alleging coerced consent and fraud; courts ruled consent was voluntary, denied annulment, upheld attorney’s fees, but deleted moral/exemplary damages for lack of evidence.
annulment of marriage
coerced consent
fraud

Case Summary (G.R. No. 132955)

Factual Background

Petitioner and private respondent married on April 13, 1988 in Puerto Princesa, Palawan. Petitioner alleged that he was forced into the marriage by threats, duress and intimidation, that he did not impregnate private respondent prior to marriage, that they never cohabited after marriage, and that he later learned that private respondent’s child died during delivery on August 29, 1988. Private respondent answered and filed a compulsory counterclaim, alleging that the marriage was entered into freely and voluntarily; that petitioner stayed with her in Palawan for almost a month after their marriage; that petitioner maintained letters to her after returning to Manila and that she personally visited him; that petitioner knew of her pregnancy which resulted in a premature birth; and that petitioner was liable for moral and exemplary damages, attorney’s fees and costs.

Trial Court Proceedings

The Regional Trial Court dismissed petitioner’s petition for annulment and awarded private respondent moral damages in the amount of P100,000, exemplary damages in the amount of P50,000, attorney’s fees in the amount of P20,000, plus costs. The judgment thus rejected petitioner’s claims of vitiated consent and other grounds asserted to invalidate the marriage.

Court of Appeals Ruling

The Court of Appeals, in CA-G.R. CV No. 51832, affirmed the RTC’s dismissal of the annulment petition and its award of attorney’s fees and costs, but reduced the awards for moral and exemplary damages to P50,000 and P25,000, respectively. The Court of Appeals denied petitioner’s motion for reconsideration, prompting the present petition for review.

Issues Presented

The Supreme Court identified the questions for resolution as whether the marriage was annulable for vitiated consent and whether petitioner should be liable for moral and exemplary damages as well as attorney’s fees and costs.

Petitioner’s Contentions

Petitioner assigned as error the Court of Appeals’ refusal to grant annulment on the ground that his consent had been obtained by fraud, intimidation, undue and improper pressure and influence, and that there was no cohabitation; and he contended that the awards of moral and exemplary damages and attorney’s fees were not authorized by law.

Respondent’s Contentions

Private respondent maintained that the marriage had been entered into freely and voluntarily; she asserted that petitioner cohabited with her for a period after the marriage, that he corresponded with her thereafter, and that he was aware of and acquiesced in her pregnancy terminating in a premature delivery; she sought moral and exemplary damages, attorney’s fees and costs.

Supreme Court’s Findings on Consent and Cohabitation

The Court affirmed the factual findings of the Court of Appeals and the trial court that petitioner freely and voluntarily married private respondent and that no threats, intimidation, duress or violence compelled him to do so. The Court relied on petitioner’s unexplained delay of not less than four years and eight months in filing the annulment suit, which suggested ulterior motives related to an existing criminal bigamy case, the absence of credible proof of effective threats, petitioner’s employment as a security guard and his failure to seek police or school security assistance or to inform the judge prior to solemnization, petitioner’s own admissions of sexual relations with private respondent and his initial identification of letters containing expressions of love, and his subsequent inconsistent recantation which the Court treated as motivated by hindsight once the letters’ evidentiary weight was realized. The Court further held that lack of cohabitation is not, by itself, a ground for annulment and becomes relevant only if it results from grounds such as fraud, intimidation or undue influence, which petitioner failed to establish.

Legal Basis for Upholding Dismissal

The Court applied the principle that factual findings of the Court of Appeals are generally binding when they coincide with the trial court’s findings, citing Valdez v. Reyes. The Court examined the elements of fraud, intimidation and duress as alleged, found the evidentiary showing insufficient, and concluded that petitioner failed to prove that his will to consent was overborne at the time of marriage. The Court underscored that petitioner had not shown that any asserted noncohabitation stemmed from a legally cognizab

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