Title
Antonio S. Quiogue, Jr. vs. Maria Bel B. Quiogue and the Republic
Case
G.R. No. 203992
Decision Date
Aug 22, 2022
Marriage nullified due to Antonio's chronic infidelity rooted in narcissistic personality disorder, deemed psychological incapacity under Article 36.
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Case Digest (G.R. No. 203992)

Facts:

Marriage and Separation:

  • Antonio S. Quiogue, Jr. (petitioner) and Maria Bel B. Quiogue (respondent) were married on October 16, 1980. They have four children: Marie Antonette, Jose Antonio, Anabel, and Maritoni.
  • The couple separated in 1998 after Maribel allegedly drove Antonio out of their conjugal home. Antonio claimed he tried to reconcile for the sake of their children but failed. He has since lived separately.

Petition for Nullity of Marriage:

  • Antonio filed a Petition for Declaration of Nullity of Marriage in 2001, alleging that both he and Maribel were psychologically incapacitated to fulfill their marital obligations. He cited a lack of mutual love, respect, and emotional support.
  • Maribel denied the allegations, stating that Antonio voluntarily left their home due to his womanizing and gambling habits. She accused him of being verbally abusive and violent.

Trial and Evidence:

  • Antonio testified that Maribel was ill-tempered, confrontational, and lacked respect for him. He admitted to having extramarital affairs but claimed Maribel’s behavior exacerbated the situation.
  • Gemarie Martin, an office staff member, corroborated Antonio’s claims, stating that Maribel often called the office to inquire about Antonio’s whereabouts and sent vulgar fax messages.
  • Dr. Valentina Del Fonso Garcia, a psychiatrist, conducted evaluations and concluded that both Antonio and Maribel were psychologically incapacitated to fulfill their marital obligations. She diagnosed Antonio with a narcissistic and histrionic personality disorder.
  • Maribel disputed Dr. Garcia’s findings, stating that her interviews were taken out of context and were related to their daughter’s treatment for depression.

RTC Decision:

  • The Regional Trial Court (RTC) granted the petition, declaring the marriage null and void under Article 36 of the Family Code. The court found both parties psychologically incapacitated based on Dr. Garcia’s evaluation.

CA Decision:

  • The Court of Appeals (CA) reversed the RTC’s decision, ruling that Antonio’s infidelity and marital problems did not constitute psychological incapacity under Article 36. The CA also questioned the methodology of Dr. Garcia’s evaluation.

Issue:

  1. Whether Antonio’s chronic infidelity and Maribel’s retaliatory behavior constitute psychological incapacity under Article 36 of the Family Code.
  2. Whether the totality of evidence, including Dr. Garcia’s psychiatric evaluation, sufficiently proves psychological incapacity.
  3. Whether the marriage between Antonio and Maribel should be declared null and void.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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