G.R. No. 231619 – 914 Phil. 664 – Criminal Law – Special Penal Laws – VAWC; Permanent Protection Order
Remedial Law – Special Proceedings – Permanent Protection Order; RA 9262 – Effect of Nullity of Marriage; Provision on Support may not be fully enforced if marriage is subsequently voided
AAA filed for a Permanent Protection Order (PPO) against her husband, Wilfredo Ruiz, citing physical, emotional, and economic abuse. On 10 September 2008, the Regional Trial Court (RTC) granted the PPO under R.A. No. 9262, directing Wilfredo to provide 50% of his income as support to AAA and their children, BBB and CCC. The order became final and executory on 30 January 2013.
AAA filed a Motion for Execution on 16 July 2013, due to Wilfredo’s non-compliance. Wilfredo opposed, arguing that the PPO was effectively revoked as AAA was cohabiting with another man and their marriage had been declared void ab initio. The RTC granted the motion and issued a Writ of Execution on February 27, 2015. Wilfredo’s subsequent motions to quash were denied by both the RTC and the Court of Appeals.
ISSUES: Whether supervening events negate Wilfredo’s liability for spousal support following the declaration of their marriage as void ab initio.
HELD: The Court recognized that while final judgments are generally immutable, supervening events can justify exceptions. The marriage between Wilfredo and AAA was declared void in a separate final judgment on March 3, 2017. According to Article 198 of the Family Code, mutual spousal support ceases once the marriage is nullified. Therefore, Wilfredo’s obligation to support AAA ceased due to the nullity of the marriage. However, he remains obligated to support his child CCC and BBB if still studying and unemployed.
Note: This is an AI-generated case digest.
