G.R. No. 130831 - Ramas vs. Commission on Elections

Sue Ann Bounsit-Torralba and Joseph B. Torralba first met in college in Cebu City in 1989.
Initially, Joseph’s conduct—characterized by drunkenness, drug use, and unsavory behavior—rejected by Sue Ann.
In December 1995, despite his earlier antics, Sue Ann accepted Joseph’s proposal to be his lover during his visits to Toledo City, where she was residing.

With Joseph already working as a seaman and in a hurry to work abroad, the couple hastily entered into a civil marriage without securing a license.
Their marriage was solemnized on January 26, 1996, in Pinamungajan, Cebu.
Soon after the marriage, Joseph left for work and thereafter repeatedly exhibited behavior that undermined marital obligations—frequent gambling, drinking, and self-indulgence.

During the course of their marriage, Joseph did not show love and respect as required by marital obligations.
He contributed his full salary during vacations only to later retract it for his vices, and he was involved in illegal activities, including drug trafficking and gambling.
Sue Ann alleged psychological incapacity on the part of Joseph due to his personal vices and erratic actions, contending that these actions rendered him unable to perform his essential marital duties.
Additional allegations arose regarding the absence of a valid marriage license and the fact that the couple did not cohabit as husband and wife prior to their marriage.

Sue Ann filed a Petition for Declaration of Nullity of Marriage before the RTC of Toledo City, alleging psychological incapacity under Article 36 of the Family Code and the lack of a marriage license.

The RTC, relying on the evidence presented—testimonies from Sue Ann, her niece Verlain, and clinical psychologist Maryjun Y. Delgado—rendered a decision on February 1, 2010, declaring the marriage null and void.
Sue Ann’s claim was bolstered by Delgado’s Psychological Assessment Report which diagnosed Joseph with Anti-Social Personality Disorder, attributing it to his dysfunctional upbringing.

The Office of the Solicitor General (OSG) intervened, filing a motion for reconsideration which was denied by the RTC on July 5, 2010.
The case was elevated to the Court of Appeals (CA) on appeal, with the CA ultimately reversing the RTC decision on October 30, 2013, declaring the marriage valid.
A subsequent motion for reconsideration by Sue Ann on the issue of the marriage license was also denied by a CA Resolution dated September 19, 2014.
The present Petition for Review on Certiorari under Rule 45 was thus filed, contesting both the reversal of the nullity finding and the CA’s refusal to resolve the issue regarding the absence of a valid marriage license.

Whether the CA erred in setting aside the RTC’s finding that Joseph was psychologically incapacitated to perform his marital obligations, despite Sue Ann’s presentation of evidence (including an expert’s Psychological Assessment Report) supporting such incapacity.
Whether the evidence presented, particularly from expert witness Delgado, sufficiently established the necessary grave, incurable, and deeply-rooted psychological incapacity required by jurisprudence.

Whether the CA committed grave abuse of discretion amounting to lack or excess of jurisdiction by refusing to rule on the validity of the marriage on the basis that there was no valid marriage license.
Whether the absence of a marriage license, which is clearly evident on the marriage certificate, is a ground sufficient to render the marriage null and void—given that the parties did not cohabit as required for the exemption provided under Article 34 of the Family Code.

Whether the procedural lapse in raising the issue of the marriage license should be given weight as it was originally averred in Sue Ann’s petition for nullity.
The appropriateness of applying Rule 45, notwithstanding potential technical or procedural deficiencies that may have affected the thorough resolution of the substantive issues.