Case Digest (G.R. No. 192164)
Facts:
Jeffrey M. Calma v. Mari Kris Santos-Calma, G.R. No. 242070, August 24, 2020, Supreme Court Third Division, Leonen, J., writing for the Court. Petitioner Jeffrey M. Calma (Jeffrey) sought a declaration that his marriage with respondent Mari Kris Santos-Calma (Kris) was void ab initio under Article 36 of the Family Code for psychological incapacity. The Regional Trial Court (RTC), Branch 51, Guagua, Pampanga dismissed his Petition for Declaration of Nullity of Marriage in a January 6, 2017 Decision; the Court of Appeals (CA) affirmed in a June 21, 2018 Decision (CA‑G.R. CV No. 109155), and denied reconsideration by Resolution dated August 22, 2018. Jeffrey then filed this Rule 45 petition for review on certiorari.Jeffrey and Kris met in February 2005, became intimate soon after, and married on August 15, 2005; their son, Josh Xian, was born December 31, 2005. Ten days after the wedding Jeffrey received work assignment abroad; Kris initially stayed with Jeffrey’s parents, later moved among relatives, and repeatedly changed phone numbers. While Jeffrey worked overseas, Kris allegedly demanded increasing sums of money (purportedly for the child), then refused to meet Jeffrey upon his return; in due course Jeffrey learned she was cohabiting with another man and had become pregnant by him, and she ceased communication and contact with their son.
In 2013 Jeffrey decided to pursue nullity proceedings. He engaged clinical psychologist Dr. Leo Ruben C. Manrique, who interviewed the parties and relatives and conducted community investigation. Dr. Manrique diagnosed Kris with schizoid personality disorder, identified maladaptive behavioral patterns and impulse-control problems, concluded the disorder began in early adulthood, was chronic and resistant to treatment, and opined that Kris was psychologically incapacitated to perform essential marital obligations. At trial Jeffrey presented three witnesses: himself, his mother, and D...(Subscriber-Only)
Issues:
- Did petitioner prove that respondent was psychologically incapacitated at the time of the marriage with the requisite gravity, juridical antecedence, and incurability under Article 36 of the Fa...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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