**Facts:**
Lucila David married Rene F. Aguas on November 24, 1981, in Mabalacat, Pampanga. They had five children: Princess Luren, Danica Lane, Sean Patrick, Sean Michael, and Samantha. On December 10, 2003, Rene filed a petition to nullify his marriage with Lucila on grounds of psychological incapacity. The properties declared as conjugal included a lot in Sunset Valley Estate, Angeles City, along with Rene’s merchandise inventory in his pawnshop and ready-to-wear business.
On December 22, 2005, the marriage was declared null and void by the RTC of Angeles City (2005 Nullity Decision). The decision also stated the partition of the conjugal properties and delivery of the presumptive legitimes of the children. However, the said decision was not registered with the Office of the Registry of Deeds, and no annotations were made on the property title. Additionally, actual partition and delivery of presumptive legitimes were not pursued.
Rene remarried Cherry S. Calilung on October 7, 2006. Rene passed away intestate on November 17, 2015. Cherry filed a petition for the settlement of Rene’s intestate estate on May 24, 2017, which was raffled off to the RTC of Angeles City, Branch 56 (Settlement Proceeding). Meanwhile, the Aguas heirs opposed this on grounds of non-compliance with Article 52 and Article 53 of the Family Code, leading to the subsequent marriage’s nullity due to non-partition of the properties and non-delivery of presumptive legitimes from the previous marriage.
On November 3, 2017, Lucila and her children filed another petition to declare Rene’s second marriage with Cherry null and void (RTC petition), which was first assigned to Branch 59, a designated Family Court, and later transferred to Branch 60. Branch 60 dismissed the case, citing a lack of jurisdiction.
**Issues:**
1. Whether Branch 59 or Branch 60 had jurisdiction over the petition for the declaration of nullity of marriage.
2. Whether Branch 60 erred in dismissing the RTC petition based on lack of jurisdiction.
3. Whether the petitioners (Aguas heirs and Lucila) were the real parties-in-interest to file the petition under the Family Code.
**Court’s Decision:**
1. **Jurisdiction:** The Court stated that jurisdiction for the declaration of nullity of a marriage under R.A. No. 8369 lies with the designated Family Court. Branch 59, being designated for family cases, had exclusive jurisdiction over the petition, and transferring the case to Branch 60 was procedurally incorrect.
2. **Error in Dismissal by Branch 60:** Since jurisdiction over family cases falls under the designated Family Court in Angeles City, namely Branch 59, Branch 60 did not hold jurisdiction over the case, affirming its dismissal.
3. **Real Parties-in-Interest:** Petitioners (Aguas heirs and Lucila) were found to lack legal standing to file a petition for nullity of the marriage under A.M. No. 02-11-10-SC which restricts such petitions solely to the husband or wife. The Aguas heirs can only question the validity of marriage in the context of a proceeding for the settlement of an estate after a spouse’s death, while Lucila cannot be considered as an injured spouse since her marriage with Rene has already been annulled.
**Doctrine:**
1. Exclusive jurisdiction over family cases, such as the declaration of nullity of marriages, resides with designated Family Courts under R.A. No. 8369.
2. Only a husband or wife may file a petition for the declaration of nullity of a void marriage under A.M. No. 02-11-10-SC, not compulsory or intestate heirs.
3. The Court reiterated the principle that where an area has designated Family Courts, they hold exclusive jurisdiction over family-related issues to the exclusion of all other courts which lack such designation.
**Class Notes:**
– **Jurisdiction:** Family courts have exclusive jurisdiction over petitions for the declaration of nullity of marriage if designated.
– **Real Party-in-Interest:** Under A.M. No. 02-11-10-SC, only the spouses directly involved in a marriage can petition for its annulment or nullity.
– **Collateral Attack Principle:** Heirs can only challenge the validity of a marriage in an estate settlement proceeding after the concerned spouse’s death.
**Historical Background:**
This case illustrates the application of procedural rules under R.A. No. 8369 (Family Courts Act of 1997) which governs the exclusive jurisdiction of designated Family Courts in the Philippines over family and marital issues, emphasizing the limitation posed by judicial regulations on who possesses the legal standing to challenge marital validity posthumously within the proper legal frameworks. It highlights the necessity of registering judicial decrees affecting marital status and property partitions with the appropriate registries for legal enforceability against third parties.
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