Case Summary (G.R. No. 102366)
Summary of Proceedings and Issues
The petition sought annulment of the marriage on grounds of vitiated consent, asserting that Orlando was coerced into marriage due to threats and undue pressure, did not cohabit with Lilia, and was misled by claims about Lilia’s pregnancy. Lilia countered that the marriage was consensual and that Orlando willingly cohabited with her and knew about her pregnancy. The RTC dismissed the petition, awarded damages and attorney’s fees, and the CA reduced the damage awards but otherwise affirmed the RTC’s ruling. The Supreme Court was tasked to resolve two main issues: (a) whether the petitioner’s consent was vitiated and thus justified annulment, and (b) whether the award of moral and exemplary damages and attorney’s fees was proper.
Supreme Court’s Review of Factual Findings
The Court emphasized that findings of fact by the CA and RTC, agreeing in this case, are generally binding and entitled to great respect. It upheld the courts’ conclusion that the petitioner freely and voluntarily married the respondent, rejecting the claim that threats, intimidation, or duress compelled the marriage. The petitioner’s delayed attempt to annul the marriage—filed more than four years after the wedding—and the lack of immediate complaint about the alleged threats undermined his credibility. The Court also noted the petitioner’s pending criminal bigamy case, suggesting a possible motive to use annulment to aid in his defense.
Analysis of Alleged Coercion and Fraud
The petitioner alleged harassment through threatening phone calls and visits by purported armed men hired by the respondent. The Court doubted the gravity of these threats given petitioner’s employment as a security guard and his failure to seek police intervention or inform the court at the time of marriage. As to fraud, the petitioner contested the respondent’s pregnancy, claiming no sexual consummation occurred and therefore he was misled. The Court found this claim to be unsubstantiated and inconsistent, especially given the petitioner’s own admission of sexual relations and the respondent’s credible testimony, corroborated by civil registry documents of the fetus’s premature birth and death.
Assessment of Letters and Evidence of Consent
The petitioner’s letters to the respondent, expressing love and concern, contradicted his claim of duress. Although he initially admitted to writing some letters but later recanted on grounds of duress, the Court found his recantation unreasonable and motivated by hindsight appreciation of their evidentiary weight. The Court emphasized that such letters reflected voluntary consent, undermining petitioner’s allegations.
On the Ground of Non-Cohabitation
The Court reiterated the legal principle that failure to cohabit, by itself, is not a ground for annulment of marriage. It only becomes relevant if resulting from valid grounds such as fraud or duress. Since the petitioner failed to prove such grounds, the non-cohabitation allegation did not justify annulment.
Award of Attorney’s Fees and Damages
The Court upheld the award of attorney’s fees to the respondent, pursuant to Article 2208(11) of the Civil Code, which allows fees when deemed just an
...continue readingCase Syllabus (G.R. No. 102366)
Case Background and Procedural History
- The case arises from a petition for annulment of marriage filed by Orlando Villanueva against his wife, Lilia Canalita-Villanueva, after almost four years and eight months of their marriage contracted on April 13, 1988, in Puerto Princesa, Palawan.
- Orlando alleged that his consent to the marriage was obtained through threats, duress, and intimidation, and that he never cohabited with Lilia, discovering later that her child died during delivery.
- Lilia answered with a compulsory counterclaim, asserting the marriage was entered into voluntarily by Orlando, evidencing cohabitation and continuing communication, and claimed entitlement to moral and exemplary damages, attorney’s fees, and costs.
- The Regional Trial Court (RTC) of Valenzuela dismissed the annulment petition and ordered Orlando to pay moral damages (P100,000), exemplary damages (P50,000), attorney’s fees (P20,000), and costs.
- The Court of Appeals affirmed the dismissal and the awarded attorney’s fees and costs but reduced the moral damages to P50,000 and exemplary damages to P25,000.
- The Court of Appeals denied Orlando’s motion for reconsideration.
- This prompted the filing of the petition for review under Rule 45 before the Supreme Court.
Issues Presented for Resolution
- Whether the marriage of Orlando Villanueva and Lilia Canalita-Villanueva may be annulled on the ground of vitiated consent caused by fraud, intimidation, undue pressure, and absence of cohabitation.
- Whether Orlando Villanueva should be liable to pay moral and exemplary damages and attorney’s fees to Lilia Canalita-Villanueva.
Factual Findings and Evidence on Consent to Marriage
- The Supreme Court acknowledged that factual findings by the Court of Appeals, which coincide with those of the RTC, are generally binding.
- Peaceable and voluntary consent to marriage is affirmed, with no compelling evidence of threats, intimidation, or duress forcing Orlando into marriage.
- Despite allegations of harassment, including threatening phone calls, visits by strangers, and the presence of “Ka Ce