G.R. No. 224673 - Rivac vs. People

Petitioner Veronica Cabacungan Alcazar filed a Complaint for annulment of marriage with respondent Rey C. Alcazar before the RTC of Malolos City on August 22, 2002.
The Complaint alleges grounds for annulment based initially on non-consummation and later on the claim of psychological incapacity.
The marriage was solemnized on October 11, 2000, by Rev. Augusto G. Pabustan, after which the couple briefly lived together for five days in San Jose, Occidental Mindoro, before separating due to respondent’s departure.

After the wedding, the couple resided briefly; however, upon returning to Manila, respondent did not stay with petitioner at her residence in Tondo, Manila.
On October 23, 2000, respondent left for Riyadh, Saudi Arabia, for work and ceased further communication (phone or letter) with petitioner.
Approximately a year and a half later, petitioner learned indirectly of respondent’s return to the Philippines, only to later discover that he had been residing with his parents in San Jose, Occidental Mindoro, rather than with her.

Petitioner argued that respondent’s absence, lack of communication, and failure to live with her implied a physical incapacity to consummate the marriage.
She further contended that respondent was psychologically incapacitated to perform the essential marital obligations—a condition allegedly rooted in his troubled childhood and manifested in a diagnosis of Narcissistic Personality Disorder.
Testimonies were given by petitioner, her mother (Lolita Cabacungan), and a clinical psychologist (Nedy L. Tayag), who evaluated both parties:

Tayag opined that respondent exhibited a pattern of grandiosity, lack of empathy, and other traits consistent with Narcissistic Personality Disorder.
The psychological report linked respondent’s alleged disorder to childhood factors such as familial instability, poverty, and neglect of emotional needs.

Despite these allegations, petitioner admitted during cross-examination that marital relations did occur after the wedding and before respondent left for Saudi Arabia.

The RTC rendered its Decision on June 9, 2004, denying the Complaint for annulment on the ground that the evidence did not establish psychological or physical incapacity.
A subsequent Motion for Reconsideration filed by the petitioner was denied by the RTC on August 19, 2004.
The Court of Appeals, in its Decision on May 24, 2006, and a later Resolution on August 28, 2008, affirmed the RTC’s ruling, emphasizing that petitioner failed to prove respondent’s incapacity.
Petitioner brought the issue before the Supreme Court through a Petition for Review on Certiorari, focusing solely on whether respondent is psychologically incapacitated to perform essential marital obligations.

Whether or not, as defined by law and established jurisprudence, respondent is psychologically incapacitated to perform the essential marital obligations of marriage.

Whether the alleged psychological incapacity existed at the time of the marriage, satisfying the requirement that such incapacity must predate the exchange of marital vows.
Whether the evidence presented—mainly petitioner’s testimony and the clinical psychologist’s report—was sufficient and reliable to substantiate a claim of grave and incurable psychological incapacity.
Whether actions such as abandonment and lack of cohabitation may be equated with, or serve as proxies for, the demonstration of a psychological disorder warranting an annulment judgment.