Case Digest (G.R. No. 236827) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
This case involves Elizabeth A. Alberto (petitioner) who sought the declaration of nullity of her marriage to Jose Luis R. Alberto (respondent) on the ground of psychological incapacity, under Article 36 of the Family Code of the Philippines. Elizabeth and Jose met in Madrid, Spain in 1995, started living together in 1996, and were married in San Fernando, Pampanga on January 14, 1998. They had two children, born in 1999 and 2003 respectively. Elizabeth testified that even before marriage, Jose exhibited irresponsible behavior including alcoholism, drug use, and depression. During their marriage, Jose engaged in an extramarital affair with a woman named Joyce David and showed continued neglect and irresponsibility toward his family, including financial neglect, physical abuse of their eldest child, and failure to fulfill his paternal and spousal obligations. A clinical psychologist, Dr. Rowena R. Belen, evaluated Elizabeth and the children and concluded that Jose had Narcissist
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Case Digest (G.R. No. 236827) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Relationship History
- Elizabeth A. Alberto (Elizabeth) and Jose Luis R. Alberto (Jose) met in Madrid, Spain, in 1995. Elizabeth was working for the Philippine Embassy, and Jose was studying for a master's degree.
- After ending previous relationships, they lived together from 1996 to 1997 in Madrid, after which Jose returned to the Philippines to find work.
- On January 14, 1998, Elizabeth and Jose married in San Fernando, Pampanga; Elizabeth went back to Madrid two days later. Jose visited Elizabeth in Spain from December 1998 to January 1999.
- Elizabeth became pregnant and gave birth to their first child, Joaquin Carlos, in September 1999.
- Claims of Psychological Incapacity and Marital Difficulties
- Elizabeth observed Jose’s irresponsible behavior even before marriage: excessive alcohol consumption, smoking cigarettes and marijuana, bouts of depression. She hoped to change him.
- Jose had an extra-marital affair with Joyce David (Joyce) while Elizabeth was working in Madrid. Elizabeth discovered romantic messages and letters from Joyce, and Jose admitted the affair. Jose promised to stop but seldom came home afterward.
- Jose and Joyce allegedly had sexual intercourse in the presence of their son Joaquin Carlos.
- Elizabeth eventually gave Jose another chance but separated sleeping arrangements after the birth of their second child in April 2003. They ceased sexual relations.
- The couple ultimately parted ways in 2008; Jose stopped communicating and financially supporting Elizabeth and their children.
- Behavioral and Psychological Evaluations
- Elizabeth testified that Jose failed to meet financial obligations, was often unemployed, suffered from depression, did not fulfill parental duties, and even physically punished his eldest child.
- Clinical psychologist Dr. Rowena R. Belen conducted psychological tests on Elizabeth and interviews with her and the children. Attempts to contact Jose failed.
- Dr. Belen diagnosed Jose with Narcissistic Personality Disorder, characterized by: inability to maintain employment; disregard for rules and family rights; neglect of wife and children; exploitative interpersonal behavior; grandiosity and entitlement; and a constant need for attention.
- Dr. Belen traced Jose’s personality disorder to childhood factors: a wealthy but emotionally neglectful and materially indulgent family background.
- A family friend, Jenelyn Abeleda, corroborated Elizabeth’s testimony regarding Jose’s irresponsibility and infidelity.
- Proceedings Below
- The Regional Trial Court (RTC), Branch 94, Quezon City, rendered a decision on January 8, 2016, declaring the marriage null and void due to Jose’s psychological incapacity, allowed Elizabeth to use her maiden name, ordered liquidation and partition of valid properties, awarded custody of the children to Elizabeth with visitation rights for Jose, and ordered both parents to support the children.
- The RTC ruled that Jose’s personality disorder showed juridical antecedence, permanence, and gravity sufficient to impair his marital obligations.
- The Republic of the Philippines moved for reconsideration, which was denied by the RTC.
- Court of Appeals (CA) Decision and Motion for Reconsideration
- The Republic elevated the case to the CA, arguing that the psychological incapacity was unproven, biased, and lacked evidence of gravity, juridical antecedence, and incurability.
- On June 30, 2017, the CA reversed the RTC decision and dismissed the petition for nullity of marriage.
- Elizabeth’s motion for reconsideration was also denied by the CA in a resolution dated January 3, 2018.
- Petition for Review on Certiorari to the Supreme Court
- Elizabeth filed the present petition raising that the CA erred in disregarding the psychological evaluation report and the trial court’s findings, and in ruling insufficient proof of Jose’s psychological incapacity.
- Initially, the Supreme Court found no reversible error but reinstated the petition after reconsideration in light of recent jurisprudence.
Issues:
- Whether the Court of Appeals erred in disregarding the psychological evaluation report presented by Elizabeth.
- Whether the Court of Appeals erred in brushing aside the factual and psychological evaluation findings of the Regional Trial Court.
- Whether the Court of Appeals erred in ruling that Elizabeth failed to prove the psychological incapacity of Jose.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)