Case Digest (G.R. No. 180668)
Facts:
The case involves Marietta C. Azcueta as the petitioner and the Republic of the Philippines, along with the Court of Appeals, as respondents. Marietta and Rodolfo Azcueta met in 1993 and were married on July 24, 1993, at St. Anthony of Padua Church in Antipolo City. At the time of their marriage, Marietta was 23 years old, and Rodolfo was 28. The couple separated in 1997 after four years of marriage and had no children. On March 2, 2002, Marietta filed a petition for the declaration of absolute nullity of their marriage under Article 36 of the Family Code with the Regional Trial Court (RTC) of Antipolo City, Branch 72, which was docketed as Civil Case No. 02-6428. Rodolfo did not appear or file an answer despite being served summons. Consequently, the RTC directed the City Prosecutor to investigate potential collusion between the parties. The prosecutor's report, dated August 16, 2002, concluded that no collusion existed. The Office of the Solicitor General later entered ...
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:
- Whether the totality of evidence presented is sufficient to prove Rodolfo’s psychological incapacity under Article 36 of the Family Code.
- 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)