Case Digest (G.R. No. 214392)
Facts:
The case involves Sue Ann Bounsit-Torralba (petitioner) and Joseph B. Torralba (respondent), with the Republic of the Philippines as the oppositor-respondent. The events leading to this case began in 1989 when Sue Ann and Joseph met while attending college in Cebu City. Their relationship was initially distant, as Joseph frequently visited Sue Ann while under the influence of alcohol and drugs. It was not until December 1995 that Sue Ann agreed to be Joseph's girlfriend, after which they hastily married on January 26, 1996, in Pinamungajan, Cebu, without a marriage license. Shortly after their marriage, Joseph left for work abroad.
During their marriage, Joseph exhibited a lack of love and respect towards Sue Ann, often contributing his salary to their conjugal funds only to request it back for his vices. He was frequently absent from their home, engaging in gambling and drinking, and displayed unreasonable jealousy towards Sue Ann's male friends, despite his own i...
Case Digest (G.R. No. 214392)
Facts:
Background of the Parties
- Sue Ann Bounsit-Torralba (petitioner) and Joseph B. Torralba (respondent) first met in 1989 while in college in Cebu City. Joseph frequently visited Sue Ann’s boarding house but was often drunk and engaged in drugs with friends, leading Sue Ann to avoid associating with him at the time.
Marriage and Early Marital Life
- In December 1995, Sue Ann accepted Joseph’s proposal to be his lover. Joseph, then working as a seaman, was in a hurry to report for work abroad, prompting them to enter into a hasty civil marriage on January 26, 1996, in Pinamungajan, Cebu, without a marriage license. Joseph left for work a month after the marriage.
Marital Issues
- During their marriage, Joseph exhibited irresponsible behavior, including gambling, drinking, substance abuse, and womanizing. He contributed his full salary to the conjugal funds but would later withdraw the money for his vices. Joseph also displayed unreasonable jealousy toward Sue Ann’s male friends while engaging in illicit relationships with other women. He frequently insulted and humiliated Sue Ann in front of friends and relatives.
Separation and Legal Action
- In 2000, Joseph was dismissed from his job for drug trafficking in Mexico. He squandered nearly a million pesos earned from illegal activities on gambling, drinking, and womanizing. Sue Ann gave birth to their only child, Elisha Kane, in 2000. In October 2001, Sue Ann left for Dubai to support her family due to Joseph’s irresponsibility. Joseph abandoned the family after their daughter’s first birthday, and Sue Ann had no further contact with him.
Petition for Nullity of Marriage
- On August 8, 2007, Sue Ann filed a Petition for Declaration of Nullity of Marriage before the Regional Trial Court (RTC) of Toledo City, Branch 59, on the grounds of psychological incapacity under Article 36 of the Family Code and the lack of a marriage license. Joseph failed to file an Answer despite being served summons.
Trial and Evidence
- Sue Ann presented herself, her niece Verlain Bounsit, and clinical psychologist Maryjun Y. Delgado as witnesses. Delgado testified that Joseph suffered from Anti-Social Personality Disorder, rooted in his dysfunctional upbringing, which rendered him psychologically incapacitated to fulfill marital obligations. Verlain corroborated Sue Ann’s testimony regarding Joseph’s vices and abusive behavior.
Issue:
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Ruling:
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Ratio:
Psychological Incapacity: The Court emphasized that psychological incapacity must be characterized by gravity, juridical antecedence, and incurability. Sue Ann’s evidence merely showed Joseph’s irresponsible and abusive behavior but failed to establish a direct link between his actions and a psychological disorder that rendered him incapable of fulfilling marital obligations. The psychological assessment report was based on one-sided accounts and lacked independent corroboration.
Marriage License Requirement: The absence of a marriage license rendered the marriage void ab initio under Article 35(3) of the Family Code. The parties did not qualify for the exemption under Article 34, as they did not cohabit as husband and wife for at least five years prior to the marriage. The Court reiterated that the solemnization of a marriage without a license violates the law and undermines the sanctity of marriage.
Conclusion:
The Supreme Court reinstated the RTC’s decision declaring the marriage null and void due to the lack of a valid marriage license. The Court found insufficient evidence to support the claim of psychological incapacity but upheld the nullity of the marriage based on the absence of a marriage license.