Aurelio v. Aurelio
REITERATIONFacts
1. The Antecedents: Danilo A. Aurelio and Vida Ma. Corazon Aurelio were married on March 23, 1988, and have two sons. On May 9, 2002, Vida filed a Petition for Declaration of Nullity of Marriage with the Regional Trial Court (RTC) of Quezon City, Branch 94. She alleged that both she and Danilo were psychologically incapacitated to perform and comply with their essential marital obligations, and that this incapacity was present prior to and during the marriage. The petition detailed specific alleged incapacities of both parties, including Danilo's lack of financial support, jealousy, and insensitivity, and Vida's emotional immaturity, low tolerance for boredom, and self-indulgence, leading to a Histrionic Personality Disorder with Narcissistic features, while Danilo allegedly suffers from a Passive Aggressive (Negativistic) Personality Disorder. 2. Procedural History: Danilo A. Aurelio filed a Motion to Dismiss the petition, arguing it failed to state a cause of action and did not meet the standards set by jurisprudence for Article 36 of the Family Code. The RTC denied this motion on January 14, 2003, and subsequently denied Danilo's Motion for Reconsideration on December 17, 2003, finding that the petition complied with the Molina doctrine and that the merits would be determined during trial. Danilo then appealed to the Court of Appeals (CA) via a petition for certiorari under Rule 65. On October 6, 2005, the CA dismissed this petition, affirming the RTC's ruling that the petition for nullity of marriage sufficiently stated a cause of action. The CA later dismissed Danilo's motion for reconsideration on October 26, 2004. 3. The Petition: Danilo A. Aurelio filed the present petition for review on certiorari under Rule 45 of the Rules of Court, seeking to set aside the CA's decision and resolution. He raises two main issues: (1) whether the CA erred in holding that the allegations in the petition for declaration of nullity were sufficient to declare the marriage void, and (2) whether the CA erred in denying his petition for certiorari despite the RTC's alleged grave abuse of discretion in denying his motion to dismiss, arguing that appeal was not a plain, adequate, or speedy remedy. Danilo contends that the petition for nullity failed to comply with key Molina guidelines regarding the root cause of incapacity, the gravity of the illness, and the statement of non-complied marital obligations.
Issue(s)
Whether the Court of Appeals violated applicable law and jurisprudence when it held that the allegations contained in the petition for declaration of the nullity of marriage are sufficient for the court to declare the nullity of the marriage between Vida and Danilo; specifically, whether the RTC committed grave abuse of discretion in denying the petitioner's motion to dismiss. Whether the Court of Appeals violated applicable law and jurisprudence when it denied petitioner’s action for certiorari despite the fact that the denial of his motion to dismiss by the trial court is patently and utterly tainted with grave abuse of discretion amounting to lack or excess of jurisdiction, and that appeal in due course is not a plain, adequate or speedy remedy under the circumstances; specifically, whether certiorari was the proper remedy.
Ruling
The Supreme Court denied the petition and affirmed the Decision and Resolution of the Court of Appeals. The Court ruled that the RTC did not commit grave abuse of discretion in denying the petitioner's motion to dismiss, and that even if there was an error, it was an error of judgment correctible by appeal, not by certiorari. The CA also correctly dismissed the petitioner's petition for certiorari.
Ratio Decidendi
On the issue of sufficiency of allegations and denial of motion to dismiss: The Court reiterated that the sufficiency of the allegations in a petition for declaration of nullity of marriage based on psychological incapacity is a matter for the Regional Trial Court (RTC) to decide at the first instance after the presentation of evidence. The Molina guidelines contemplate a situation where parties have presented their evidence and a decision has been reached after due hearing. It would be too burdensome for the Supreme Court to resolve at first instance whether the allegations are sufficient to substantiate a case for psychological incapacity. Each case involving Article 36 of the Family Code must be treated distinctly and judged according to its own attendant facts, guided by experience and findings of experts. Therefore, the RTC did not commit grave abuse of discretion in denying the petitioner's motion to dismiss. On the issue of certiorari as a remedy: The Court emphasized that as a general rule, the denial of a motion to dismiss, being an interlocutory order, is not reviewable by certiorari. The petitioner's remedy is to reiterate the grounds in his motion to dismiss as defenses in his answer, proceed to trial, and, in case of an adverse decision, appeal the decision in due time. The existence of this adequate remedy removed the underpinnings of his petition for certiorari in the Court of Appeals. Even assuming arguendo that the RTC erred in denying the motion to dismiss, such an error would be one of judgment, correctible by appeal, not an abuse of discretion correctible by certiorari. Thus, the CA properly dismissed the petitioner's petition for certiorari.
Main Doctrine
The sufficiency of the allegations in a petition for declaration of nullity of marriage based on psychological incapacity is a matter for the Regional Trial Court to decide after presentation of evidence, and a denial of a motion to dismiss on this ground is generally not reviewable by certiorari, but by appeal.