Case Digest (G.R. No. 258705)
Facts:
Arnold S.I. Alfonso v. Michelle Pamintuan Alfonso and Republic of the Philippines, G.R. No. 258705 [Formerly UDK No. 17095], July 16, 2025, Supreme Court Third Division, Gaerlan, J., writing for the Court. Petitioner Arnold S.I. Alfonso married respondent Michelle Pamintuan Alfonso on May 9, 1998 in Gapan City; the Republic of the Philippines, through the Office of the Solicitor General (OSG), later appealed adverse rulings. Arnold filed a Petition for Declaration of Nullity of Marriage under Article 36 of the Family Code on April 23, 2015 in RTC, Branch 35, Gapan City, Civil Case No. 4705-15, alleging Michelle’s psychological incapacity.The Regional Trial Court, in a Decision dated April 2, 2018, granted Arnold’s petition and declared the marriage null and void under Article 39 (as cited by the RTC disposition), ordering civil registrars to cancel the marriage record. The Republic, through the OSG, appealed to the Court of Appeals (CA), which in CA-G.R. CV No. 113342 reversed the RTC in a Decision rendered November 26, 2020 and memorialized by a Resolution dated June 23, 2021. Arnold then filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court.
Factual background established at trial showed that Arnold and Michelle reconnected in 1997, engaged in a relationship that produced an unexpected pregnancy, and married thereafter. During the marriage they had three children, operated businesses, and lived in Gapan City; but Arnold testified to Michelle’s chronic attention-seeking, extravagant spending, incurrence of large debts, diversion of business funds, refusal to perform household duties or parental responsibilities, emotional coldness and sexual refusal, and eventual elopement with another man in 2010. Arnold offered testimony of himself and a mutual friend, Primo Urbano, and subm...(Subscriber-Only)
Issues:
- Whether the marriage of Arnold S.I. Alfonso and Michelle Pamintuan Alfonso should be declared null and void on account of Michelle’s psychological incapacity under Article 36 of the...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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