Case Digest (G.R. No. 174451)
Facts:
The case involves Veronica Cabacungan Alcazar as the petitioner and Rey C. Alcazar as the respondent. The events leading to the case began with their marriage on October 11, 2000, officiated by Rev. Augusto G. Pabustan at his residence. Following their wedding, the couple resided together for only five days in San Jose, Occidental Mindoro, before returning to Manila. Shortly thereafter, on October 23, 2000, Rey left for Riyadh, Saudi Arabia, to work as an upholsterer. During his time abroad, he failed to communicate with Veronica, despite her attempts to reach him multiple times.
Approximately a year and a half later, Veronica learned from a co-teacher that Rey was returning to the Philippines. However, upon his arrival in March 2002, Rey did not return to Veronica's residence but instead went to live with his parents in San Jose. Veronica's efforts to locate Rey were unsuccessful, and she concluded that he was physically incapable of consummating their marriage, w...
Case Digest (G.R. No. 174451)
Facts:
Marriage and Initial Cohabitation
- Petitioner Veronica Cabacungan Alcazar and respondent Rey C. Alcazar were married on 11 October 2000 by Rev. Augusto G. Pabustan at his residence.
- After the wedding, the couple lived together for five days in San Jose, Occidental Mindoro, the hometown of respondent's parents.
- They then returned to Manila, but respondent did not live with petitioner at her residence in Tondo, Manila.
Respondent's Departure and Lack of Communication
- On 23 October 2000, respondent left for Riyadh, Saudi Arabia, to work as an upholsterer.
- While in Riyadh, respondent did not communicate with petitioner by phone or letter. Petitioner attempted to contact him five times but received no response.
- Approximately a year and a half later, petitioner learned from a co-teacher that respondent was returning to the Philippines. However, respondent did not inform petitioner of his arrival.
Respondent's Return and Separation
- Upon returning to the Philippines in March 2002, respondent went directly to his parents' house in San Jose, Occidental Mindoro, instead of reuniting with petitioner.
- Petitioner traveled to San Jose to confront respondent but was informed that he had been living with his parents since his return.
- Respondent never contacted petitioner after his return, leading her to conclude that he was physically incapable of consummating the marriage and that reconciliation was impossible.
Legal Proceedings
- Petitioner filed a Complaint for annulment of marriage on 22 August 2002, citing respondent's physical incapacity under Article 45(5) of the Family Code.
- The RTC dismissed the Complaint, finding no evidence of respondent's physical incapacity. The Court of Appeals affirmed this decision.
Issue:
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Ruling:
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Ratio:
Psychological Incapacity under Article 36:
- Psychological incapacity must be grave, juridically antecedent, and incurable.
- It must be more than mere difficulty, refusal, or neglect in performing marital obligations.
- The burden of proof lies with the petitioner, and any doubt should be resolved in favor of the validity of the marriage.
Insufficiency of Evidence:
- Petitioner's evidence, including testimonies and the psychological report, did not sufficiently establish respondent's psychological incapacity.
- The psychological report relied on information provided by petitioner, who was not impartial, and failed to explain how respondent's alleged Narcissistic Personality Disorder rendered him incapable of fulfilling marital obligations.
Abandonment and Infidelity:
- Respondent's abandonment and alleged infidelity do not constitute psychological incapacity under the Family Code.
- These actions, while grounds for legal separation, do not meet the legal standard for nullity of marriage.
Presumption of Validity of Marriage:
- The State has a strong interest in preserving marriage, and the presumption is always in favor of its validity.
- Petitioner failed to overcome this presumption with clear and convincing evidence of respondent's psychological incapacity.
Conclusion:
- The Supreme Court upheld the lower courts' decisions, emphasizing that an unsatisfactory marriage does not equate to a null and void marriage under Philippine law.
- The Petition was denied, and the marriage between petitioner and respondent remained valid.