G.R. No. L-21098; May 31, 1963
Carmen P. Novino and Rodolfo Novino, petitioners, vs. The Court of Appeals, Lina Y. Fuentes, Rafael Fuentes and People’s Homesite and Housing Corporation (PHHC), respondents.

FACTS

Petitioners Carmen P. Novino and Rodolfo Novino sought a review of a Court of Appeals decision. This Court initially dismissed their petition via a resolution stating it was “for lack of merit.” Petitioners’ counsel then filed a motion arguing that this resolution violated Section 12, Article VIII of the Constitution , as it failed to state the factual and legal bases for the dismissal. Counsel contended the resolution did not interpret or clarify any law pertinent to the petition but merely denied it without reason.
The core substantive dispute originated from Carmen Novino’s sale of a parcel of land she had acquired from the respondent PHHC. She later sought to annul this sale, alleging she did not obtain the consent of Rodolfo Novino, whom she claimed was her husband. The Court of Appeals found that Carmen and Rodolfo’s marriage was null and void ab initio because both had living spouses from prior, undissolved marriages at the time of their union. Consequently, the appellate court ruled the sale was valid, as no spousal consent from Rodolfo was required.

ISSUE

The primary issue is whether the Supreme Court’s resolution dismissing the petition for review “for lack of merit” without an elaborate explanation contravenes the constitutional mandate to state the facts and the law on which the decision is based. A secondary, substantive issue is whether the Court of Appeals erred in not applying Article 144 of the Civil Code to the property relations between Carmen and Rodolfo.

RULING

The Supreme Court denied the motion for reconsideration. On the procedural issue, the Court held that its brief resolution of dismissal was not a “decision” within the contemplation of the constitutional requirement. Such resolutions merely signify that the petition for review is not being entertained as a matter of sound judicial discretion, in accordance with Rule 46 of the Rules of Court. The Court clarified that review of Court of Appeals decisions is discretionary, not a matter of right. This practice, patterned after that of the U.S. Supreme Court, aids in managing the Court’s docket. The facts and law are already contained in the appealed decision, and there is no obligation to detail reasons for denying a discretionary review.
On the substantive issue, the Court found no error in the Court of Appeals’ judgment. The lower court correctly deemed Article 144 of the Civil Code inapplicable. This article governs property acquired by a man and woman living together as husband and wife under a void marriage or without marriage, applying rules on co-ownership. The Court of Appeals impliedly found that at the time Carmen acquired the property, she and Rodolfo were not living under such circumstances, rendering Article 144 immaterial. Furthermore, the Court added that even if the sale were defective due to lack of consent, the right to annul would pertain to Rodolfo’s heirs, not to Carmen, who cannot invoke her own fault to invalidate a transaction she executed. The Court also noted the sale proceeds were used for Rodolfo’s hospital expenses. Therefore, the petition lacked merit.