G.R. No. 167391 - Phil-Ville Development and Housing Corp. vs. Bonifacio

Petitioner Marietta C. Azcueta and respondent Rodolfo B. Azcueta met in 1993 and were married on July 24, 1993, at St. Anthony of Padua Church in Antipolo City.
At the time of marriage, Marietta was 23 years old while Rodolfo was 28.
The couple separated in 1997 after four years of marriage and had no children.

On March 2, 2002, petitioner filed a petition for declaration of absolute nullity of marriage before the RTC of Antipolo City, Branch 72, under Article 36 of the Family Code (Civil Case No. 02-6428).
Respondent failed to appear and file an answer despite due service, prompting the trial court to direct an investigation by the City Prosecutor for allegations of collusion, which was later dismissed.

Petitioner alleged that Rodolfo was psychologically incapacitated to perform essential marital obligations.

She claimed that he was emotionally immature, irresponsible, and perpetually dependent on his mother for financial support.
Specific evidence included his failure to seek employment and reliance on his mother for essential needs, including housing and sustenance, even after assurances of obtaining a job.
Petitioner further testified about his unsatisfactory approach to marital intimacy and his recurrent physical violence when intoxicated.

Florida de Ramos, a relative, corroborated that Rodolfo was not gainfully employed at the time of their marriage and continued to rely on his mother.
Testimony confirmed that despite claims of employment, he did not actually work and depended on his mother's support.

Dr. Cecilia Villegas, a psychiatrist, conducted a psychological evaluation of the petitioner and the respondent.
She diagnosed Rodolfo with Dependent Personality Disorder marked by severe inadequacy and a deep-seated cross-identification with his dominant mother.
Dr. Villegas explained that such a disorder, being rooted in early personality development, rendered him psychologically incapacitated to fulfill marital obligations.
Her testimony, supported by clinical observations and detailed reasoning, was pivotal to the trial court’s original decision.

On October 25, 2004, the RTC found that the totality of evidence substantiated the claim of psychological incapacity and declared the marriage null and void ab initio.
An Amended Decision dated July 19, 2005, corrected a typographical error concerning the respondent’s first name.

The Solicitor General appealed the RTC decision, contesting the sufficiency and basis of the psychiatric evaluation and the evidence of preexisting psychological defects.
The CA reversed the RTC decision, ruling that the petitioner failed to sufficiently prove the respondent’s psychological incapacity or its preexistence prior to the marriage.

The Supreme Court, reviewing the entire record and the guidelines under Article 36, scrutinized the evidence and expert testimonies.
It emphasized the state’s policy of protecting the sanctity of marriage and the importance of deference to the trial court’s findings of credibility and expert evaluation.

Whether the totality of the evidence presented is adequate to establish that Rodolfo is psychologically incapacitated to comply with his essential marital obligations.

Does the evidence of Rodolfo’s emotional immaturity, dependency on his mother, and failure to perform marital duties equate to psychological incapacity under Article 36?
Was the alleged psychological condition present prior to the celebration of the marriage as required by law?

Whether the reliance on expert testimony, particularly that of Dr. Cecilia Villegas, is sufficient to substantiate the claim of permanent and incurable psychological incapacity.

Can the psychiatric evaluation based on petitioner’s account and corroborated evidence serve as conclusive proof?
Was the absence of a direct examination of the respondent by the expert a defect in the evidence?

Whether the CA’s reversal of the RTC decision, on grounds of insufficient evidence and misinterpretation of psychological incapacity, was justified in view of the totality of evidence and established guidelines.