G.R. No. 216655 - Cayabyab-Navarrosa vs. Navarrosa

Petitioner Lovelle Shelly S. Cayabyab-Navarrosa met respondent Mark Anthony E. Navarrosa at the Perpetual Help Hospital in BiAan, Laguna where she was an intern in the College of Medicine and he was a nurse in the Emergency Room Department.
They began their romantic relationship in 2001, during which respondent shared personal issues including resentment toward his parents and preferential treatment given to his eldest sibling.

In 2004, respondent went to Singapore for work, and petitioner eventually joined him.
When petitioner became pregnant, the couple returned to the Philippines and were married on August 15, 2006, in Pulang Lupa II, Las PiAas City, only to resume their stay in Singapore following the wedding.
Due to respondent’s unemployment at the time of marriage, petitioner became the primary, and sole, financial supporter.

While in Singapore, respondent exhibited secretive behaviors (e.g., frequently turning off his mobile phone) and displayed a pattern of verbal and physical aggression toward petitioner including tantrums and attempts to hit her.
Respondent’s repeated absences and prioritization of socializing with friends over family obligations led to petitioner facing antenatal and postpartum challenges alone.
Petitioner discovered that money, meant for her childbirth expenses, was misappropriated by respondent to support his extended family.
Instances of emotional and physical abuse, as well as consistent lack of financial support and responsible behavior, became evident from early signs in their conjugal life.

In August 2007, a final confrontation occurred after which respondent abandoned the marriage, leaving petitioner without any contact.
Petitioner subsequently filed a Petition for Declaration of Absolute Nullity of Marriage on July 19, 2010, alleging respondent’s psychological incapacity characterized by abandonment, failure to provide support, and a lack of love.
Despite proper summons, respondent failed to file an answer, and the case proceeded to trial where petitioner and her witnesses, including a clinical psychologist and a neighbor, testified regarding respondent’s dysfunctional behavior and personality traits.

The Regional Trial Court (RTC) of Guimba, Nueva Ecija, Branch 33, in its Decision dated June 29, 2011, declared the marriage null and void on the ground of psychological incapacity.
The decision was sustained when the Office of the Solicitor General (OSG) sought reconsideration in an Order dated September 5, 2011, but later the Court of Appeals (CA) reversed and set aside the RTC’s decision on January 29, 2015, on the grounds that the evidence was insufficient to establish psychological incapacity.

Whether the Court of Appeals erred in reversing the Regional Trial Court’s ruling which declared the marriage null and void based on respondent’s alleged psychological incapacity.

The core issue examined was if the evidence pertaining to respondent’s consistent neglect, abandonment, and failure to perform essential marital obligations amounted to the legal threshold of psychological incapacity under Article 36 of the Family Code.
The determination also involved addressing whether expert testimony and collateral evidence (from petitioner, her sister, and common friends) were sufficient to prove such incapacity without the respondent’s participation.