Tuason v. CA

G.R. No. 116607 (April 10, 1996)

Facts:

In 1989, Maria Victoria Lopez Tuason filed a petition for annulment of her marriage to Emilio R. Tuason in the Regional Trial Court, Branch 149, Makati. They were married on June 3, 1972 and had two children. Maria Victoria alleged that Emilio was psychologically incapacitated at the time of their marriage, which became evident through violent altercations, drug abuse, infidelity, and financial irresponsibility. She claimed that Emilio left the conjugal home in 1984, cohabited with multiple women, and provided minimal support for their family, leading her to seek financial assistance from relatives.

Emilio denied the allegations, asserting that they had a normal marriage for the first ten years and that the issues arose due to Maria Victoria's lack of respect and her own drug use. He claimed that his absence from the home was a temporary measure for a "cooling-off period" and that he faced financial difficulties due to business reverses.

The trial commenced on March 30, 1990, with Maria Victoria presenting four witnesses and various documentary evidence, including articles about Emilio's relationships and his drug-related legal issues. Emilio's counsel filed for a postponement of the hearing scheduled for May 11, 1990, which was granted. However, Emilio failed to appear at the rescheduled hearing on June 8, 1990, leading the court to declare that he waived his right to present evidence. The trial court subsequently ruled on June 29, 1990, declaring the marriage null and void due to psychological incapacity and awarding custody of the children to Maria Victoria.

Emilio received notice of the decision on August 24, 1990, but did not appeal. On September 24, 1990, Maria Victoria filed a motion for the dissolution of the conjugal partnership, which Emilio opposed. On October 17, 1990, Emilio, through new counsel, filed a petition for relief from the judgment, claiming he was denied due process due to his absence being caused by medical treatment for drug dependency. The trial court denied this petition on August 8, 1991.

Emilio appealed the denial to the Court of Appeals, which dismissed the appeal on July 29, 1994, affirming the trial court's order. Emilio then filed a petition for review on certiorari.

Legal Issues:

1. Whether Emilio's petition for relief from judgment was warranted under the circumstances.
2. Whether Emilio was denied due process in the annulment proceedings.
3. The applicability of Articles 48 and 60 of the Family Code regarding the role of the prosecuting attorney in annulment cases.

Arguments:

• Petitioner (Emilio):

  • Claimed that he was denied due process because he was not able to present evidence due to his medical confinement.
  • Argued that the trial court should have ordered the prosecuting attorney to intervene to prevent collusion, as required by the Family Code.
  • Asserted that he had a valid and meritorious defense against the annulment based on the nature of their marriage and his support for the family.

• Respondent (Maria Victoria):

  • Contended that Emilio's absence and failure to appeal were due to his own negligence and that he had not provided sufficient justification for his non-appearance.
  • Argued that the trial court's findings regarding psychological incapacity were binding and that the absence of prosecutorial intervention did not invalidate the proceedings.

Court's Decision and Legal Reasoning:

The Supreme Court ruled against Emilio, affirming the Court of Appeals' decision. The Court held that a petition for relief from judgment is an equitable remedy that is only available in exceptional cases where no other adequate remedy exists. Emilio's failure to appeal the trial court's decision within the reglementary period rendered the judgment final and executory.

The Court found that Emilio's claims of due process violations were unfounded. His absence from the hearings was attributed to his counsel's negligence, which is not excusable under the law. The Court emphasized that notice sent to counsel is binding on the client, and the failure of counsel to inform Emilio of the adverse judgment did not constitute a valid ground for setting aside the judgment.

Regarding the role of the prosecuting attorney, the Court noted that the Family Code's provisions were not strictly applicable in this case since Emilio actively participated in the proceedings and contested the annulment. The absence of collusion was evident from the nature of the litigation, and the prosecuting attorney's intervention was not necessary.

Significant Legal Principles Established:

1. A petition for relief from judgment is only granted in exceptional circumstances where the party has no other adequate remedy and must demonstrate a meritorious defense.
2. The negligence of counsel is not a valid ground for setting aside a judgment that is valid and regular on its face.
3. The prosecuting attorney's role in annulment proceedings is to prevent collusion and ensure the integrity of evidence; however, if the defendant actively participates in the case, the absence of prosecutorial intervention does not invalidate the proceedings.