In Cynthia S. Bolos v. Danilo T. Bolos, the Supreme Court clarified the scope of A.M. No. 02-11-10-SC, the Rule on Declaration of Absolute Nullity of Void Marriages and Annulment of Voidable Marriages. The Court ruled that this rule applies exclusively to marriages entered into during the effectivity of the Family Code, which took effect on August 3, 1988. This decision underscores the importance of determining when a marriage was solemnized, as it dictates the procedural rules applicable in cases seeking to nullify or annul such unions.

When Does the Family Code Govern Marriage Nullity?

Cynthia Bolos filed a petition to declare her marriage to Danilo Bolos null and void based on psychological incapacity under Article 36 of the Family Code. The Regional Trial Court (RTC) granted the petition. However, Danilo appealed, which the RTC denied due course due to his failure to file a motion for reconsideration, as required by Section 20 of A.M. No. 02-11-10-SC. The Court of Appeals (CA) reversed the RTC’s decision, stating that the motion for reconsideration requirement did not apply because the marriage occurred before the Family Code’s enactment. Cynthia then elevated the case to the Supreme Court, questioning the CA’s interpretation.

The central issue before the Supreme Court was whether A.M. No. 02-11-10-SC applies to marriages solemnized before the Family Code’s effectivity. Cynthia argued that the rule should govern petitions for nullity regardless of when the marriage took place. Danilo, on the other hand, contended that since their marriage was solemnized in 1980, A.M. No. 02-11-10-SC did not apply.

The Supreme Court sided with Danilo, emphasizing the explicit language of Section 1 of A.M. No. 02-11-10-SC, which states:

Section 1. Scope – This Rule shall govern petitions for declaration of absolute nullity of void marriages and annulment of voidable marriages under the Family Code of the Philippines.

The Rules of Court shall apply suppletorily.

The Court found the language of A.M. No. 02-11-10-SC to be clear and unambiguous. As such, the Supreme Court applied the plain meaning rule, stating:

A cardinal rule in statutory construction is that when the law is clear and free from any doubt or ambiguity, there is no room for construction or interpretation. There is only room for application.

Building on this principle, the Court determined that the phrase “under the Family Code” refers to marriages entered into during the effectivity of the Family Code, which began on August 3, 1988. This interpretation aligns with the rule’s intent to set a clear distinction between marriages governed by the Family Code and those solemnized under the Civil Code. Because the Bolos’ marriage occurred in 1980, it falls outside the scope of A.M. No. 02-11-10-SC.

The Court rejected Cynthia’s argument that substantial justice warranted a relaxation of the rules in her favor. The Supreme Court emphasized the need for faithful compliance with procedural rules to prevent delays and ensure the orderly conduct of judicial business. The Court also highlighted the importance of the right to appeal, particularly in cases involving the institution of marriage, which is constitutionally protected.

Moreover, the Supreme Court underscored the constitutional policy of protecting and strengthening the family as the basic autonomous social institution and marriage as its foundation. In line with this policy, the Court recognized the need to provide Danilo with the fullest opportunity to present his appeal. The Court quoted Article 1 of the Family Code, which states:

Article 1. Marriage is a special contract of permanent union between a man and a woman entered into in accordance with law for the establishment of conjugal and family life. It is the foundation of the family and an inviolable social institution whose nature, consequences, and incidents are governed by law and not subject to stipulation, except that marriage settlements may fix the property relations during the marriage within the limits provided by this Code.

This case highlights the importance of adhering to procedural rules while also safeguarding the fundamental right to appeal, especially in matters concerning marriage and family. The Supreme Court, in balancing these competing interests, ultimately prioritized the correct application of the law and the preservation of the institution of marriage.

FAQs

What was the key issue in this case?	The key issue was whether A.M. No. 02-11-10-SC, which requires a motion for reconsideration before an appeal in cases of marriage nullity, applies to marriages solemnized before the Family Code’s effectivity. The Supreme Court determined it does not.
When did the Family Code take effect?	The Family Code took effect on August 3, 1988. This date is crucial in determining which laws and rules govern marriage-related cases.
What is A.M. No. 02-11-10-SC?	A.M. No. 02-11-10-SC is the Rule on Declaration of Absolute Nullity of Void Marriages and Annulment of Voidable Marriages. It sets forth the procedural rules for cases seeking to nullify or annul marriages under the Family Code.
What is the plain meaning rule?	The plain meaning rule is a principle of statutory construction stating that if the language of a law is clear and unambiguous, it should be applied literally without interpretation. The Court relied on this rule to interpret A.M. No. 02-11-10-SC.
Why is the date of marriage important in nullity cases?	The date of marriage is important because it determines which set of laws and rules apply. Marriages solemnized before August 3, 1988, are generally governed by the Civil Code, while those after are governed by the Family Code.
What was the basis for seeking the nullity of marriage in this case?	The petitioner, Cynthia Bolos, sought the nullity of her marriage based on psychological incapacity under Article 36 of the Family Code.
What did the Court say about the right to appeal?	The Court emphasized that the right to appeal is an essential part of the judicial system and should be protected, especially in cases involving the institution of marriage.
What is the State’s policy regarding marriage?	The State recognizes marriage as an inviolable social institution and the foundation of the family. It is committed to protecting and strengthening the family.

This ruling clarifies the procedural requirements for marriage nullity cases based on the date the marriage was solemnized. Understanding this distinction is essential for legal practitioners and individuals seeking to navigate family law matters.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Cynthia S. Bolos vs. Danilo T. Bolos, G.R. No. 186400, October 20, 2010