Title
Azcueta vs. Republic
Case
G.R. No. 180668
Decision Date
May 26, 2009
Marriage declared null due to husband's psychological incapacity (Dependent Personality Disorder), proven by expert testimony and evidence of inability to fulfill marital obligations.
Font Size:

Case Digest (G.R. No. 180668)

Facts:

Background of the Parties

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

Petition for Nullity of Marriage

  • On March 2, 2002, Marietta filed a petition for the declaration of absolute nullity of marriage under Article 36 of the Family Code, citing Rodolfo's psychological incapacity to fulfill marital obligations. Rodolfo failed to appear or file an answer despite proper service of summons.

Collusion Investigation

  • The trial court directed the City Prosecutor to investigate possible collusion between the parties. Prosecutor Wilfredo G. Oca found no collusion, and the Office of the Solicitor General (OSG) entered its appearance for the Republic of the Philippines.

Petitioner’s Allegations

  • Marietta claimed Rodolfo was emotionally immature, irresponsible, and overly dependent on his mother. He failed to secure employment, relied on his mother for financial support, and exhibited violent behavior when drunk. Their sexual relationship was unsatisfactory, and Rodolfo refused to have children, claiming he was not ready.

Witness Testimonies

  • Florida de Ramos, Rodolfo’s cousin, corroborated Marietta’s claims, testifying that Rodolfo was unemployed, dependent on his mother, and pretended to have a job.
  • Dr. Cecilia Villegas, a psychiatrist, testified that Rodolfo suffered from Dependent Personality Disorder, which rendered him psychologically incapacitated to fulfill marital obligations. She explained that the disorder was rooted in his early development and was incurable.

RTC Decision

  • The Regional Trial Court (RTC) declared the marriage null and void ab initio, finding Rodolfo psychologically incapacitated based on the evidence presented.

CA Reversal

  • The Court of Appeals (CA) reversed the RTC decision, ruling that Marietta failed to prove Rodolfo’s psychological incapacity existed at the time of marriage or that it was grave and incurable. The CA attributed Rodolfo’s behavior to immaturity rather than psychological incapacity.

Issue:

  1. Whether the totality of evidence presented is sufficient to prove Rodolfo’s psychological incapacity under Article 36 of the Family Code.
  2. Whether the CA erred in reversing the RTC’s decision declaring the marriage null and void.

Ruling:

The Supreme Court granted the petition and reinstated the RTC’s decision declaring the marriage null and void. The Court found that Marietta sufficiently proved Rodolfo’s psychological incapacity based on the evidence, including expert testimony and witness corroboration.

Ratio:

  • (Unlock)

Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.