Case Digest (G.R. No. 222068)
Facts:
In G.R. No. 222068, decided on July 25, 2023 under the 1987 Constitution, petitioner Arthur A. Candelario and respondent Marlene E. Candelario were lawfully married on June 11, 1984, and bore one child on May 14, 1985. In October 1987, Marlene left for Singapore to work as a domestic helper and left the child in Arthur’s custody. Thereafter, Arthur engaged in frequent nightclub visits, formed a relationship with another woman, and cohabited with her in the former conjugal home. Discovering the affair upon her unannounced return in October 1989, Marlene permanently separated from Arthur and secured custody of their child, who was thereafter raised by Marlene’s relatives. Arthur, however, continued living with his new partner and fathered four more children. Over twenty years later, on January 18, 2013, Arthur filed a Petition for Declaration of Nullity of Marriage under Article 36 of the Family Code, alleging psychological incapacity predating the marriage. Marlene failed to answCase Digest (G.R. No. 222068)
Facts:
- Background of marriage and family circumstances
- Arthur A. Candelario and Marlene E. Candelario married in a civil ceremony on June 11, 1984; their only child was born on May 14, 1985.
- In October 1987 Marlene went to Singapore to work as a domestic helper, leaving their child with Arthur.
- Separation and subsequent family developments
- While Marlene was abroad, Arthur frequented nightclubs, met and cohabited with another woman; Marlene learned of the affair in October 1989 and separated.
- Marlene’s relatives cared for the child; Arthur continued his relationship with his partner and had four more children.
- Petition for nullity in the Regional Trial Court
- On January 18, 2013, Arthur filed a Petition for Declaration of Nullity of Marriage under Article 36 (psychological incapacity) of the Family Code.
- Marlene did not answer; the RTC investigated and found no collusion; pre-trial terminated and the case proceeded to trial on the merits.
- Trial proceedings and expert testimony
- Arthur testified and offered the judicial affidavit and psychiatric report of Dr. Daisy L. Chua-Daquilanea, diagnosing him with Dependent Personality Disorder characterized as severe, juridically antecedent, and incurable.
- The State and Marlene presented no evidence; the case was submitted for resolution after Arthur rested.
- RTC judgment and post-judgment proceedings
- On March 6, 2015, the RTC denied the petition, ruling that Article 36 of the Family Code (effective August 3, 1988) could not be applied retroactively to a 1984 marriage; the December 7, 2015 order denied reconsideration.
- Arthur filed a Rule 45 Petition for Review on Certiorari before the Supreme Court; after procedural resolutions and impleading the OSG (Marlene remained absent), the Court resolved to take up the merits.
Issues:
- Retroactivity of the Family Code’s psychological incapacity ground
- Can Article 36 of the Family Code be applied to marriages solemnized before its effectivity on August 3, 1988?
- Sufficiency of proof of psychological incapacity
- Did Arthur present clear and convincing evidence that his Dependent Personality Disorder was grave, incurable, and juridically antecedent to his marriage with Marlene?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)