G.R. No. 116607 , April 10, 1996
Emilio Tuason, Petitioner, vs. Court of Appeals and Maria Victoria L. Tuason, Respondents.

FACTS

Maria Victoria Tuason filed a petition to annul her marriage to Emilio Tuason on the ground of his psychological incapacity under Article 36 of the Family Code. She alleged his drug use, infidelity, abandonment, violence, and financial irresponsibility, which demonstrated an inability to fulfill marital obligations. Emilio denied these allegations, claiming marital problems arose from his wife’s disrespect and her own affair, and attributed business gossip to his media work. After Maria Victoria presented her evidence, the trial court scheduled Emilio’s presentation. His counsel sought a postponement, which was granted. On the reset date, Emilio failed to appear. The trial court thus deemed him to have waived his right to present evidence and submitted the case for decision.
The trial court rendered a judgment annulling the marriage. Emilio did not appeal this decision. Subsequently, Maria Victoria filed a motion for the dissolution of the conjugal partnership. Emilio then filed a petition for relief from the annulment judgment with the trial court, which was denied. He appealed this denial to the Court of Appeals, which affirmed the trial court’s order. Emilio elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s denial of Emilio Tuason’s petition for relief from judgment.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The Court held that a petition for relief from judgment is an equitable remedy available only when a judgment is rendered against a party through fraud, accident, mistake, or excusable negligence, and that party has no other adequate remedy. In this case, Emilio’s failure to appear at the scheduled hearing and present his evidence constituted a waiver of his right to do so. His subsequent failure to appeal the adverse judgment within the reglementary period rendered that judgment final and executory.
The Court found that Emilio failed to prove that his failure to appeal was due to fraud, accident, mistake, or excusable negligence. His own inaction led to the loss of his right to appeal. A petition for relief cannot serve as a substitute for a lost appeal. Furthermore, the Court emphasized that factual findings of the trial court, especially on the matter of psychological incapacity, are generally binding when supported by evidence. Since Emilio waived his right to present countervailing evidence, the trial court’s findings based on the evidence presented by Maria Victoria attained finality. The petition for relief was therefore correctly denied.