Case Digest (G.R. No. 259322)
Facts:
Nellie Y. Chan Tee Ten v. Willy Q. Tee Ten and the Republic of the Philippines, G.R. No. 259322, August 06, 2025, Supreme Court Third Division, Inting, J., writing for the Court.Willy Q. Tee Ten filed a petition with the Regional Trial Court (Branch 261, Pasig City) on October 28, 2003 (amended December 30, 2003) seeking declaration of nullity of his marriage to Nellie Y. Chan Tee Ten (married January 22, 1995) on the ground of psychological incapacity under Article 36 of the Family Code and dissolution of their conjugal property regime. Willy alleged long-standing domineering, abusive and manipulative behavior by Nellie that predated and persisted after marriage and recounted instances of her hostility toward his relatives and acts he characterized as psychological abuse of their children.
The record included a Psychological Assessment Report by Dr. Natividad A. Dayan diagnosing Nellie with Narcissistic Personality Disorder with paranoid features and concluding her incapacity was grave, incurable, and had antecedents; Dr. Dayan based her report on clinical interviews with Willy, standardized tests administered to Willy, and collateral interviews with witnesses because Nellie refused personal examination. Nellie denied the allegations, asserted instead that Willy abused the children and her, and questioned the reliability of Dr. Dayan’s report; she presented a psychological evaluation by Dr. Elias Adamos who opined Nellie was not incapacitated but admitted Nellie had withheld information that could have affected his conclusions.
The trial court (RTC) rendered a Decision on November 3, 2016 declaring the marriage void for psychological incapacity and denied Nellie’s motion for reconsideration by Order dated May 4, 2017. The Court of Appeals (Special Fourteenth Division) in CA-G.R. CV No. 109458 affirmed the RTC in a Decision dated May 4, 2021 and denied Nellie’s motion for reconsideration in a Resolution dated December 13, 2021. Nellie then filed a petition for review under Rule 45 of the Rules of Court before the Supreme Court. On July 27, 2022 the Supreme Court impleaded the Republic of the Philippines (Office of the Solicitor General) as a respondent and required comments; the OSG and Willy filed comments opposing the petition, arguing the issues were factual and that the lower courts properly found psychological incapacity.
Nellie’s principal arguments before the Supreme Court contested the probative value of Dr. Dayan’s report because Nellie was not personally examined, asserted that Willy was the abuser and contracted the marriage in bad faith (seeking forfeiture under Article 147), disputed the CA’s failure to find Willy...(Subscriber-Only)
Issues:
- In a Rule 45 petition, may the Supreme Court review the lower courts’ factual findings on psychological incapacity?
- Did the RTC and the Court of Appeals correctly declare the marriage void under Article 36 of the Family Code on the ground of Nellie’s psychological incapacity?
- Is a psychological evaluation based on collateral information admissible and probative when the subject refuses personal examination?
- Do Nellie’s counter-allegations of physical, sexual, emotional, financial, and psychological abuse by Willy, or the claim that Willy contracted the marriage in bad faith, negate the finding of her psychological incapacity or establish Willy’s incapacity instead?
- Should the Supreme Court determine support pendente lite and liquidate and partition the part...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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