G.R. No. 132955 ; October 27, 2006
Orlando Villanueva, petitioner, vs. Hon. Court of Appeals and Lilia Canalita-Villanueva, respondents.

FACTS

Petitioner Orlando Villanueva filed a petition for annulment of his marriage to private respondent Lilia Canalita-Villanueva, solemnized on April 13, 1988. He alleged his consent was vitiated by threats, duress, and intimidation, claiming Lilia’s relatives, including an alleged NPA member, coerced him into the marriage under the pretext that she was pregnant with his child. Orlando further asserted he never cohabited with Lilia and later learned the child died after delivery.
Private respondent Lilia opposed the petition, contending the marriage was entered into freely and voluntarily. She asserted that Orlando stayed with her after the wedding, corresponded with her, and was aware of her pregnancy. She also filed a compulsory counterclaim seeking moral and exemplary damages, attorney’s fees, and costs. The Regional Trial Court dismissed the petition for annulment and ordered Orlando to pay damages. The Court of Appeals affirmed the dismissal but reduced the monetary awards.

ISSUE

The core issues are: (1) whether the marriage is voidable on the ground of vitiated consent due to fraud, intimidation, or undue influence; and (2) whether the awards of moral and exemplary damages and attorney’s fees to Lilia are legally justified.

RULING

The Supreme Court partly granted the petition. It affirmed the dismissal of the annulment case but deleted the awards for moral and exemplary damages. On the first issue, the Court upheld the concurrent factual findings of the lower courts that Orlando’s consent was not vitiated. His claim of coercion was deemed unconvincing, noting his prolonged inaction of over four years before filing the suit, which suggested the action was motivated by his pending bigamy case. His allegation of fraud, based on Lilia’s purported false pregnancy, was also rejected as unsupported by credible evidence.
On the second issue, the Court ruled that the award of moral damages lacked sufficient basis. While the institution of an unfounded lawsuit can cause mental anguish, Lilia failed to present clear and convincing proof of such suffering during trial. Mere allegations in pleadings are insufficient; actual testimony and evidence are required. Consequently, with no valid award for moral damages, the grant of exemplary damages, which by law is ancillary to moral, temperate, or compensatory damages, must also be deleted. The award of attorney’s fees and costs was sustained as justified under the circumstances.