Facts:

The case involves Claudine Monette Baldovino-Torres as the petitioner and Jasper A. Torres and the Republic of the Philippines as the respondents. The legal proceedings commenced when Claudine filed a Petition for Declaration of Nullity of Marriage under Article 36 of the Family Code, claiming her marriage to Jasper, solemnized on July 10, 2002, was null and void ab initio due to Jasper's psychological incapacity. Claudine and Jasper, who initially met in 2000 through text messaging, soon developed a relationship and married after Claudine became pregnant. Their marriage was marked by ongoing challenges, particularly as Jasper demonstrated a reluctance to maintain employment and increasingly irresponsible behavior, leading to domestic tensions, including alcohol abuse and aggression towards Claudine. Claudine eventually left Jasper, seeking employment in Manila and later Singapore, while attempts at reconciliation failed after she discovered his infidelity.

In the Regional T

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Facts:

Parties and Background

• Petitioner: Claudine Monette Baldovino-Torres
• Respondents: Jasper A. Torres and the Republic of the Philippines
• The case involves a petition for declaration of nullity of marriage filed by Claudine against Jasper on the ground of psychological incapacity pursuant to Article 36 of the Family Code.

Formation and Development of the Relationship

• The couple met in 2000 through text messaging and mutual acquaintances, which eventually led to a romantic involvement.
• Claudine became pregnant with their child, Justin Clyde, further cementing the relationship despite initial objections from Claudine’s mother.
• The marriage was solemnized on July 10, 2002, in Makati City before Judge Encarnacion Jaja MoyaABalbastro, after which they resided in San Pedro, Laguna.

Marital Life and Emerging Issues

• Early indicators of marital issues included:
• Jasper’s frequent nocturnal outings with friends and irregular sleeping habits.
• His repeated job instability, characterized by short stints in employment and a heavy reliance on his parents’ financial support.
• Escalation of problems:
• Jasper’s worsening drinking habits led him to force Claudine into non-consensual sexual relations when intoxicated.
• Increasing aggressiveness and irresponsibility in fulfilling marital obligations were consistently observed.
• Despite some hopes that fatherhood might alter his behavior, Jasper’s pattern of irresponsibility persisted.

Evidence and Testimonies at the RTC

• Claudine’s direct testimony chronicled the evolution of Jasper’s behavior and its dire impact on the marriage.
• Testimonies of other witnesses included:
• Nora Ng Baldovino (Claudine’s mother) who described Jasper as irresponsible and overly dependent on his parents.
• Clinical Psychologist Dr. Nedy Tayag, who conducted multiple psychological evaluations and testified that Jasper suffered from Antisocial Personality Disorder—characterized by impulsivity, irresponsibility, and a pervasive disregard for the rights of others.
• The psychological evidence detailed:
• Jasper’s disorder as grave, chronic, and incurable by any means of clinical intervention.
• The manifestation of a longstanding personality defect rooted in his upbringing, notably influenced by an overindulgent maternal figure and a lack of corrective paternal supervision.

Procedural History in Lower Courts

• Regional Trial Court (RTC):
• On January 30, 2017, the RTC declared the marriage null and void ab initio based on Jasper’s psychological incapacity, dissolving the absolute community of property between the parties.
• The decision was anchored on both Claudine’s testimony and the expert report of Dr. Tayag.
• Motion for Reconsideration:
• The Office of the Solicitor General (OSG) filed a Motion for Reconsideration challenging the RTC decision.
• Although there was a contention regarding the timeliness of the filing, the OSG argued that the proper reckoning of time should be based on its receipt of the RTC decision (received on April 4, 2017) rather than on the public prosecutor’s earlier receipt.
• Court of Appeals (CA):
• On March 22, 2019, the CA reversed the RTC ruling, finding that the totality of the evidence was insufficient to establish the gravity of Jasper’s psychological disorder under Article 36 of the Family Code.
• A subsequent CA Resolution on July 9, 2019, denied Claudine’s motion for reconsideration, leading to the petition for review on certiorari before the Supreme Court.

Issue:

Whether the Court of Appeals erred in not giving due credence to the expert testimony of Dr. Tayag:

• Did the CA improperly discount the evidence indicating that Jasper suffered from a grave, chronic, and incurable personality disorder?
• Whether such expert testimony should be given weight given that it demonstrated Jasper’s inability to perform essential marital obligations.

Whether the CA erred in ruling that the totality of evidence did not establish that Jasper’s disorder met the criteria under Article 36 of the Family Code:

• Whether the behavioral patterns, in conjunction with the expert’s findings, fulfilled the doctrinal elements of psychological incapacity (gravity, juridical antecedence, and incurability).
• Whether the evidence presented by both ordinary and expert witnesses should have led to a declaration of nullity of marriage.

Whether the appeal before the CA should have been dismissed on procedural grounds due to the alleged finality and executory nature of the RTC decision:

• Whether the timing of the OSG’s filing is to be reckoned from the receipt by the OSG rather than the public prosecutor, thus rendering the Motion for Reconsideration timely.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)