Castro v. Castro
REITERATIONFacts
1. The Antecedents: Private respondent Lamberto R. Castro filed a petition for annulment of marriage against petitioner Isabelita S. Castro on July 1, 1998, alleging psychological incapacity under Article 36 of the Family Code. The parties were married in 1958 and had four children, but had been living apart for years. Private respondent claimed petitioner was irresponsible, violent, had failed to show love and affection, and had an illicit affair, exhibiting neurotic and psychotic tendencies. 2. Procedural History: The Regional Trial Court (RTC) of Valenzuela, Branch 75, granted the petition for annulment on August 19, 1998, after petitioner failed to file an answer and present evidence. Petitioner filed a motion to set aside the judgment, alleging lack of jurisdiction due to improper summons service. The RTC initially set aside the decision to allow petitioner to present contrary evidence but later affirmed its original decision on May 5, 1999, deeming petitioner to have waived her right to present evidence due to repeated postponements. The RTC denied petitioner's motion for reconsideration on July 1, 1999, and subsequently dismissed her appeal on September 20, 1999, maintaining its August 19, 1998 decision. The decision became final and executory. 3. The Petition: Petitioner filed a petition for certiorari under Rule 65 of the Rules of Court, seeking to nullify the RTC's decision and subsequent orders. She argued that the RTC lacked jurisdiction due to invalid service of summons, that the finding of psychological incapacity was baseless, that the RTC erred in not setting the case for pre-trial and trial, and that the dismissal of her appeal was improper. The Supreme Court found that petitioner was afforded due process, had acknowledged receipt of the summons, and submitted to the jurisdiction of the court by filing motions. The Court also noted that the decision had become final and executory and that private respondent had passed away.
Issue(s)
Whether the trial court acquired jurisdiction over the person of the petitioner. Whether the trial court acted with grave abuse of discretion in rendering the decision annulling the marriage. Whether the trial court acted with grave abuse of discretion in denying petitioner's appeal.
Ruling
The petition is DISMISSED. The Decision of the Regional Trial Court of Valenzuela, Metro Manila, Branch 75, dated August 19, 1998, and its Orders issued respectively on May 5, 1999, July 1, 1999, and September 20, 1999, in Civil Case No. 180-V-98, are AFFIRMED.
Ratio Decidendi
On the issue of jurisdiction: The Court found that the trial court acquired jurisdiction over the petitioner. Although petitioner claimed improper service of summons, the records showed she personally acknowledged receipt of the summons and petition. Furthermore, even assuming improper service, petitioner submitted herself to the jurisdiction of the court when she filed a motion to set aside the judgment. The Court noted that petitioner was afforded due process and was given an opportunity to present contrary evidence after her motion was granted, but she and her counsel failed to appear on the scheduled hearings, thereby waiving her right to present such evidence. On the issue of grave abuse of discretion in rendering the decision: The Court found no grave abuse of discretion. The trial court's finding of psychological incapacity was based on the ex parte presentation of evidence, including the testimony of a clinical psychologist, after petitioner failed to appear and contest the petition. Petitioner's claim that the allegations were false and that the private respondent had ulterior motives was not substantiated. The Court reiterated that the failure to appear at the scheduled hearings, despite being given the opportunity, led to the waiver of her right to present contrary evidence. On the issue of grave abuse of discretion in denying the appeal: The Court found no grave abuse of discretion. The trial court correctly maintained its decision and dismissed the appeal. The Court emphasized that the decision had already become final and executory, and judgment was entered. The Court also cited Section 24(b) of the Rule on Declaration of Absolute Nullity of Void Marriages and Annulment of Voidable Marriages, which states that if a party dies after the entry of judgment, the judgment becomes binding upon the parties and their successors in interest in the settlement of the estate.
Main Doctrine
A party who voluntarily submits to the jurisdiction of the court by filing a motion to set aside a judgment, and is subsequently given an opportunity to present contrary evidence but fails to appear on scheduled hearings, is deemed to have waived such right and cannot later claim lack of jurisdiction. Furthermore, even if the judgment of nullity is rendered, if a party dies after the entry of judgment, the judgment becomes binding upon the parties and their successors in interest in the settlement of the estate.