G.R. No. 196201 - Duque III vs. Veloso

Jeffrey M. Calma and Mari Kris Santos-Calma met in February 2005 while working as crew members at Jollibee.
Within a month of meeting, they became sexually intimate, and Kris subsequently became pregnant.
Despite Kris’s admitted unsuitability to raise a family, Jeffrey proposed, and they were married in civil rites on August 15, 2005.

Shortly after their wedding, Jeffrey received an overseas contract which required him to work in the Middle East for three years.
To manage the separation, both parties agreed that Kris would live with Jeffrey’s parents in Pampanga during his absence, partly due to Kris’s poor relationship with her own parents.
On December 31, 2005, Kris gave birth to their son, Josh Xian, while the couple continued their separate living arrangements.

After some months, Kris expressed a desire to stay with her family in Bulacan, prompting Jeffrey to comply temporarily.
Subsequently, Kris encountered personal conflict, leading to arrangements for her to stay at Jeffrey’s sister’s house in Quezon City.
Jeffrey noticed escalating requests for money by Kris, always justified on the pretext of tending to their son’s needs, even as her demands grew without clear, concrete justification.
In 2008, Kris engaged in behaviors that aroused Jeffrey’s suspicion, such as frequently changing her mobile numbers and requesting additional funds under claims of being in “deep trouble.”

Upon Jeffrey’s return from abroad, he found that Kris would not meet or communicate with him despite his efforts to initiate contact by visiting Bulacan.
Testimonies from Kris’s parents and other family members revealed that she had begun cohabiting with another man and was pregnant by this other partner.
During confrontations, Kris exhibited no remorse and attributed his absence to him working abroad, ultimately ceasing any communication or visitation with either Jeffrey or their son.

In 2013, Jeffrey sought to have his marriage declared null on the ground of psychological incapacity.
A clinical psychologist, Dr. Leo Ruben C. Manrique, was engaged to conduct interviews with Jeffrey, Kris, and their relatives.
Dr. Manrique’s assessment concluded that:

Kris suffered from schizoid personality disorder;
She demonstrated maladaptive behavioral patterns; and
Her condition rendered her incapable of performing the essential marital obligations owing to a chronic and incurable personality defect.

Jeffrey presented three witnesses—himself, his mother, and Dr. Manrique—to support his petition for nullity.

The Guagua Regional Trial Court issued a January 6, 2017, Decision dismissing Jeffrey’s petition for nullity on the ground that he failed to sufficiently prove the gravity, juridical antecedence, and incurability of Kris’s alleged psychological incapacity.
The Court of Appeals, in its June 21, 2018 Decision, affirmed the Regional Trial Court’s ruling, and the subsequent Motion for Reconsideration filed by Jeffrey was denied.
Jeffrey then filed a Petition for Review on Certiorari, prompting the Supreme Court to review whether the totality of evidence demonstrated psychological incapacity as defined under Article 36 of the Family Code.

Whether the evidence on record sufficiently demonstrates that Kris suffered from psychological incapacity as required by Article 36 of the Family Code, having the necessary attributes of gravity, juridical antecedence, and incurability.
Whether the totality of evidence, including the expert testimony of Dr. Manrique and other collateral evidence, is adequate to establish Kris’s psychological incapacity without mandating a direct, personal examination by a physician or psychologist.
Whether the dismissal of Jeffrey’s petition for nullity of marriage by the Regional Trial Court and its affirmation by the Court of Appeals was erroneous in light of the established jurisprudence on psychological incapacity.