Yu v. Reyes-Carpio
REITERATIONFacts
The Antecedents: This case originates from a petition for the declaration of nullity of marriage filed by petitioner Eric U. Yu against private respondent Caroline T. Yu. The core of the dispute revolves around the parties' respective claims of psychological incapacity to perform their marital obligations, which forms the basis for the nullity of their marriage. Ancillary to this main issue are the related matters of child custody, spousal support, and the liquidation and distribution of their property, which are typically consequential to a declaration of nullity. Procedural History: The case was initially filed with the Regional Trial Court (RTC) of Pasig City, Branch 163. An order was issued by Judge Leili Cruz Suarez regarding the partial offer of evidence. Subsequently, the private respondent moved for the resolution of the nullity issue, while the petitioner opposed, advocating for simultaneous resolution of all issues. After Judge Suarez's inhibition, the case was re-raffled to Branch 261, presided over by Judge Agnes Reyes-Carpio. Judge Reyes-Carpio granted the private respondent's Omnibus Motion, ordering that the declaration of nullity of marriage be resolved first, deferring evidence on custody, support, and property relations. The RTC denied the petitioner's motion for reconsideration. The petitioner then filed a Petition for Certiorari with the Court of Appeals (CA), assailing the RTC orders. The CA affirmed the RTC's decisions, leading to the present petition before the Supreme Court. The Petition: The petitioner filed a Petition for Certiorari under Rule 65 of the Rules of Court, seeking to annul the Court of Appeals' Decision that affirmed the RTC's Orders. The petitioner argues that the CA committed grave abuse of discretion by upholding the RTC's decision to submit the main issue of nullity of marriage for resolution ahead of the reception of evidence on custody, support, and property relations. The petitioner contends that such a procedure would lead to an ambiguous and fragmentary judgment and that the reception of evidence on these ancillary matters is necessary for a complete adjudication. The core of the petition is that the RTC, by deferring evidence on these related issues, acted with grave abuse of discretion, and the CA erred in not finding so.
Issue(s)
Whether or not the CA committed grave abuse of discretion amounting to lack of jurisdiction in holding that a petition for certiorari is not a proper remedy for the Petitioner. Whether or not the CA committed grave abuse of discretion amounting to lack or excess of jurisdiction in upholding the Respondent Judge in submitting the main issue of nullity of marriage for resolution ahead of the reception of evidence on custody, support, and property relations. Whether or not the reception of evidence on custody, support, and property relations is necessary for a complete and comprehensive adjudication of the parties’ respective claims and defenses.
Ruling
The petition is DISMISSED. The Court of Appeals Decision affirming the Orders of Judge Agnes Reyes-Carpio, finding no grave abuse of discretion amounting to lack or excess of jurisdiction, is AFFIRMED.
Ratio Decidendi
On the propriety of Certiorari and Grave Abuse of Discretion: The Court reiterated that a Petition for Certiorari under Rule 65 is a proper remedy only when a tribunal, board, or officer exercising judicial or quasi-judicial functions has acted without or in excess of jurisdiction, or with grave abuse of discretion amounting to lack or excess of jurisdiction, and there is no other plain, speedy, and adequate remedy in the ordinary course of law. Grave abuse of discretion requires a showing that the act was done in a capricious or whimsical exercise of judgment, equivalent to a lack of jurisdiction, or a patent and gross evasion of a positive duty. The Court found that the petitioner failed to demonstrate that the RTC Orders deferring the presentation of evidence on custody, support, and property relations, and the CA's affirmation thereof, were patent and gross, or done in a capricious or whimsical manner. The assailed orders were interlocutory, and certiorari is appropriate for such orders only when the requisites of jurisdiction or grave abuse of discretion are met, and appeal would not suffice. Since these requisites were not met, the proper recourse should have been an appeal in due course of the judgment on the merits. On submitting the main issue of nullity of marriage for resolution ahead of custody, support, and property relations: The Court found no grave abuse of discretion on the part of Judge Reyes-Carpio. The RTC did not deny the reception of evidence on custody, support, and property relations but merely deferred it. This deferment was based on Section 19 and 21 of A.M. No. 02-11-10-SC (Rule on Declaration of Absolute Nullity of Void Marriages and Annulment of Voidable Marriages), which allow the reception of evidence on these ancillary matters only after a decision granting the petition for nullity is rendered, or upon entry of judgment, and before a final decree is issued. The Court clarified that this procedure is consistent with Articles 50 and 51 of the Family Code, which provide for the liquidation, partition, and distribution of properties, as well as custody and support, to be determined after the final judgment granting the nullity of marriage. On the necessity of reception of evidence on custody, support, and property relations for a complete adjudication: The petitioner's argument that deferring evidence on these incidents would lead to an ambiguous and fragmentary judgment was deemed speculative and without merit. The Court reiterated that A.M. No. 02-11-10-SC clearly allows for the deferment of such evidence. The trial court may receive evidence on these matters after a judgment granting the petition but before the decree of nullity or annulment is issued, as was sought to be complied with by Judge Reyes-Carpio. The Court upheld the legal presumption that a trial judge can fairly weigh and appraise the evidence submitted by the parties, and that the trial court's decision on the matter is left to its wisdom and legal soundness. Therefore, the CA correctly found no grave abuse of discretion on the part of the RTC.
Main Doctrine
A petition for certiorari under Rule 65 is not the proper remedy to assail interlocutory orders unless it is shown that the issuing tribunal acted without or in excess of jurisdiction, or with grave abuse of discretion amounting to lack or excess of jurisdiction, and that the order is patently erroneous and appeal would not afford adequate and expeditious relief. Errors in judgment, not of jurisdiction, are correctible only by appeal.