G.R. No. 248569 - Cabutaje vs. Cabutaje

Ericson C. Cabutaje (Ericson) married Romelia A. Cabutaje (Romelia) in Lasam, Cagayan on January 2, 2003.
They had a daughter, Keirah Angela Cabutaje, born on February 24, 2003.
Initially living with Ericson's parents, Romelia was encouraged by Ericson's mother to work abroad.
Romelia went to Taiwan to work, leaving Ericson to care for their daughter.

Romelia's financial support became sporadic, prompting Ericson to also apply for work in Taiwan.
While in Taiwan, the couple seldom met due to distant workplaces, straining the marriage.
Romelia ceased providing consistent support and eventually left for the Philippines at contract's end.
Upon return, she left their child with her sister when she left for Hong Kong to work as a domestic helper.
Romelia engaged in a new romantic relationship, abandoning her familial obligations.

On August 10, 2012, Ericson filed a petition for declaration of nullity of marriage before the RTC, citing psychological incapacity under Article 36 of the Family Code.
The RTC found both spouses psychologically incapacitated, declaring the marriage void ab initio and awarded custody of the child to Ericson.
The Office of the Solicitor General (OSG) moved for reconsideration, which the RTC denied.
The Court of Appeals (CA) reversed the RTC decision citing insufficient evidence, mainly discrediting the psychologist's report due to lack of personal examination of Romelia and failure to identify root causes of the disorders.
Ericson filed a motion for reconsideration with the CA, which was denied.

Dr. Nedy Tayag, clinical psychologist, prepared a report diagnosing Ericson with narcissistic personality disorder and Romelia with histrionic personality disorder with anti-social features.
Dr. Tayag did not personally examine Romelia but based her assessment on interviews with Ericson, his sister, and a mutual friend (Zunega).
Romelia's psychological disorder was traced to childhood, including a spoiled upbringing and lenient parental discipline.

Ericson argued that the psychological incapacity was grave, incurable, and juridically antecedent, supported by clinical and factual evidence.
He cited jurisprudence allowing expert opinion even without personal examination of the alleged incapacitated spouse.
The OSG contended lack of sufficient evidence, disputing the psychologist’s methodology and emphasizing that emotional immaturity or infidelity alone does not void a marriage.

Whether the evidence sufficiently proves the psychological incapacity of either or both spouses to declare the marriage void under Article 36 of the Family Code.
Whether the lack of personal examination of the allegedly incapacitated spouse by the clinical psychologist invalidates the psychological incapacity findings.
Whether the psychological incapacity of Romelia existed prior to the marriage (juridical antecedence).