Facts:

This case revolves around a petition for review on certiorari filed by Elizabeth A. Alberto (the Petitioner) against Jose Luis R. Alberto and the Republic of the Philippines (the Respondents) concerning the declaration of nullity of marriage between Elizabeth and Jose. The marriage took place on January 14, 1998, in San Fernando, Pampanga, after Elizabeth and Jose met in Madrid, Spain in 1995. Their relationship continued until they had two children, but along the way, Elizabeth observed several troubling behaviors from Jose, including alcohol abuse, infidelity with another woman named Joyce David, and neglect of family responsibilities.

Despite Elizabeth's willingness to work through their issues, the relationship deteriorated, leading to their eventual separation in 2008 without Jose being supportive or communicative. Elizabeth filed a petition with the Regional Trial Court (RTC) in Quezon City, which initially ruled in her favor on January 8, 2016, declaring the marriage

...

Facts:

Background and Relationship of the Parties

• Elizabeth A. Alberto and Jose Luis R. Alberto met in Madrid, Spain in 1995 during Elizabeth’s tenure as Cultural Assistant at the Philippine Embassy and while Jose was pursuing his master's degree.
• After ending previous relationships, they became sweethearts and cohabited in Madrid from 1996 to 1997 until Jose returned to the Philippines for work.
• They were married on January 14, 1998, in San Fernando, Pampanga while Elizabeth was on vacation in the Philippines; shortly after, she resumed her work in Madrid and Jose remained in the Philippines.
• Their relationship produced children: Joaquin Carlos A. Alberto, born on September 18, 1999, and Ma. Teresa A. Alberto, born in April 2003.

Marital Troubles and Allegations

• Elizabeth alleged that even before the marriage, Jose exhibited irresponsible behavior including excessive drinking, smoking cigarettes and marijuana, and experiencing bouts of depression.
• Jose embarked on an extramarital affair with Joyce David while Elizabeth was working in Madrid; evidences included romantic messages, letters, and a photograph sent by Joyce to Elizabeth.
• Despite Jose acknowledging the affair and vowing to end it, his behavior continued to cause marital discord.
• Elizabeth eventually ceased marital relations; she stopped sleeping in the same room with him and had no sexual contact with him since 2003.

Evidence and Testimonies Regarding Psychological Incapacity

• Elizabeth accused Jose of neglecting his financial, emotional, and parental duties, including failing to support the family, neglecting decision-making, and even resorting to physical punishment of their child.
• Clinical psychologist Dr. Rowena R. Belen conducted an evaluation based on interviews with Elizabeth and the children, and various psychological tests (conducted on Elizabeth), concluding that Jose suffers from Narcissistic Personality Disorder.
• Dr. Belen’s report detailed characteristics including irresponsibility, defiance of moral rules, self-centeredness, lack of empathy, and a grandiose sense of entitlement—attributing these to Jose’s childhood environment where he was materially pampered yet emotionally deprived.
• Family friend Jenelyn Abeleda corroborated Elizabeth’s claims, testifying to Jose’s irresponsible behavior and witnessing him in compromising situations.

Procedural History

• The Regional Trial Court (RTC) rendered its Decision on January 8, 2016, declaring the marriage null and void ab initio on the ground of psychological incapacity of Jose, and ordered ancillary reliefs (e.g., use of Elizabeth’s maiden name, liquidation of community property, and custody arrangements).
• The Republic filed a Motion for Reconsideration, which was denied by the RTC.
• The Court of Appeals (CA) reversed the RTC Decision on June 30, 2017, holding that the evidence, including expert testimonies, did not sufficiently establish the gravity, juridical antecedence, and incurability of Jose’s alleged psychological incapacity; the CA dismissed the petition for nullity.
• Elizabeth moved for reconsideration before the CA, which was denied on January 3, 2018.
• Subsequently, the petition was reinstated by the Supreme Court on motion for reconsideration, based on recent jurisprudence regarding psychological incapacity.

Issue:

Whether the lower court erred in not giving due credence to the petitioner’s psychological evaluation report.

• The issue focuses on whether there was a deviation from established jurisprudence in discounting the psychological evaluation made by Dr. Belen and the subsequent report by Dr. Adamos.

Whether the court erred in dismissing the findings and evaluations of the trial court regarding psychological incapacity.

• This issue examines if the CA appropriately brushed aside the RTC’s thorough evaluation of evidence concerning Jose’s capacity to perform his marital obligations.

Whether the petitioner failed to prove that Jose possessed the requisite psychological incapacity based on clear and convincing evidence.

• This issue challenges whether the psychometric evidence and witness testimonies were sufficient to meet the burden of proving the grave, incurable, and juridically antecedent psychological incapacity of the respondent at the time of the marriage.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)