Arrieta v. Arrieta
REITERATIONFacts
The Antecedents: Cresencio Arrieta (Cris) and Melania T. Arrieta were married in 1973. In 1991, Melania left for the United States, obtaining a divorce in 1992 and remarrying in 1993. Cris filed a petition for declaration of nullity of their marriage in 2001, alleging Melania's psychological incapacity due to abandonment and failure to support their family. Procedural History: The Regional Trial Court (RTC) of Davao City granted Cris's petition in 2004, declaring the marriage void ab initio. This decision became final in December 2004. Over seven years later, in February 2012, Melania filed a petition for annulment of judgment with the Court of Appeals (CA), claiming lack of jurisdiction and extrinsic fraud. The CA annulled the RTC decision, not on the grounds raised by Melania, but due to a denial of due process stemming from allegedly defective service of summons. The Petition: Cris filed a petition for review on certiorari with the Supreme Court, assailing the CA's decision. He argued that the CA erred in annulling the RTC's decision, contending that the service of summons by publication, as ordered by the RTC, was a valid extraterritorial service under the third mode of Section 15, Rule 14 of the Rules of Court, and that Melania was estopped by laches from questioning the judgment after such a long delay.
Issue(s)
Whether the Court of Appeals erred in granting Melania's petition for annulment of judgment, considering the validity of the extraterritorial service of summons. Whether the service of summons by publication, without sending a copy to the defendant's last known address, constitutes a denial of due process that warrants annulment of judgment. Whether Melania is barred by laches or estoppel from filing a petition for annulment of judgment, and the presumption of regularity in the performance of official duties.
Ruling
The Supreme Court granted the petition, set aside the CA's decision, and reinstated the RTC's decision declaring the marriage void ab initio.
Ratio Decidendi
On the CA's grant of the petition for annulment of judgment and the validity of the extraterritorial service of summons: The Court held that while a petition for annulment of judgment is an equitable remedy, it is allowed only in exceptional cases where ordinary remedies are no longer available. The grounds are limited to extrinsic fraud and lack of jurisdiction. However, the Court has recognized denial of due process as a valid ground, as a violation of due process rights is a jurisdictional defect. The CA annulled the RTC decision based on denial of due process due to defective service of summons, finding that Cris should have both published the summons and sent a copy to Melania's last known address. The Court found Cris's arguments tenable. Section 15, Rule 14 of the Rules of Court allows for extraterritorial service of summons in three modes: (1) personal service, (2) publication with sending a copy to the last known address, and (3) "in any other manner the court may deem sufficient." The RTC's order for publication, without explicitly requiring service by registered mail to the last known address, fell under the third mode. The Court reasoned that the RTC's choice of service was justified given Melania's estrangement and residence abroad without informing Cris of her foreign address, making it futile to send a copy to her last known address. The publication, therefore, constituted substantial compliance. On whether the service of summons by publication constitutes a denial of due process: The Court addressed the issue of whether the service of summons by publication, without sending a copy to the defendant's last known address, constitutes a denial of due process that warrants annulment of judgment. The Court's analysis focused on the validity of the extraterritorial service of summons and whether the chosen method complied with due process requirements. The Court found that the RTC's choice of service was justified given Melania's estrangement and residence abroad without informing Cris of her foreign address, making it futile to send a copy to her last known address. The publication, therefore, constituted substantial compliance. On the issue of laches and estoppel, and the presumption of regularity: Regardless of any defects in the service of summons, the Court ruled that Melania's petition for annulment of judgment was barred by estoppel by laches. The principle of laches dictates that unreasonable delay in asserting a right warrants a presumption of abandonment. Given that Melania and Cris had been separated since 1991, Melania had obtained a divorce and remarried, and Cris had informed her of his intention to file for nullity, it was inconceivable that she only became aware of the RTC decision over seven years later. Her actions and prolonged silence estopped her from claiming denial of due process. The Court also invoked the presumption of regularity in the performance of official duties, stating that Melania bore the burden of proving any irregularity in the court's directive for service of summons or the choice of the publishing newspaper. Without evidence to the contrary, the regularity of the publication and the court's order must stand. The Court concluded that the CA erred in granting Melania's petition for annulment of judgment. The RTC's decision, which had attained finality, was reinstated.
Main Doctrine
A petition for annulment of judgment based on denial of due process due to defective service of summons may be barred by laches or estoppel, especially when the defendant had knowledge of the proceedings and unreasonably delayed in assailing the judgment.