GR 214593; (July, 2019) (Digest)
G.R. No. 214593 July 17, 2019
DANA S. SANTOS, Petitioner vs. LEODEGARIO R. SANTOS, Respondent
FACTS
Petitioner Dana S. Santos and respondent Leodegario R. Santos were married in 1987. In 2003, Leodegario filed a petition to declare their marriage null and void on the ground of Dana’s psychological incapacity. After trial, the Regional Trial Court (RTC) granted the petition. Dana initially filed a notice of appeal but withdrew it to instead file a Petition for Relief from Judgment with the RTC, alleging extrinsic fraud and mistake prevented her from presenting evidence. The RTC denied her petition. Dana then elevated the case to the Court of Appeals (CA) via a petition for certiorari.
During the CA proceedings, the parties entered into a compromise agreement to transfer their conjugal properties to their children. The CA subsequently issued a Resolution declaring the case closed and terminated based on this agreement. Later, Dana filed a Motion to Reopen, alleging Leodegario’s non-compliance with the compromise. The CA denied her motion, noting Leodegario had shown compliance while Dana had not. Dana’s motion for reconsideration was likewise denied.
ISSUE
Whether the Court of Appeals committed grave abuse of discretion in denying Dana’s Motion to Reopen the petition for certiorari, which assailed the denial of her Petition for Relief from Judgment against the RTC’s decision nullifying her marriage.
RULING
The Supreme Court denied the petition. The legal logic is anchored on the nature and finality of a compromise agreement and the proper remedy against a judgment declaring a marriage void. First, a compromise agreement, once approved by the court, has the force of res judicata and is immediately executory. Dana’s Motion to Reopen was correctly denied as she failed to prove her own compliance with the agreement while Leodegario demonstrated his. The CA’s closure of the case based on the compromise was proper.
Second, and more fundamentally, Dana pursued the wrong remedy from the start. A Petition for Relief from Judgment under Rule 38 is a special civil action that must be filed directly in the trial court that rendered the judgment, not in the appellate court. Her proper recourse from the RTC’s decision declaring the marriage void was a timely appeal via a notice of appeal or a petition for review under the Rule on Declaration of Absolute Nullity of Void Marriages. By filing a Petition for Relief from Judgment in the CA, she invoked an unavailable remedy. The CA’s dismissal of her petition, albeit on other grounds, was ultimately correct. A petition for certiorari under Rule 65 cannot correct errors of judgment, only errors of jurisdiction, and Dana failed to prove the RTC acted without jurisdiction in denying her Petition for Relief.