Case Digest (G.R. No. 253981)
Facts:
Marie Anne Grace Chua-Mascarinas v. Martin S. Mascarinas, Jr., G.R. No. 253981, July 07, 2025, the Supreme Court Third Division, Dimaampao, J., writing for the Court.Petitioner Marie Anne Grace Chua-Mascarinas and respondent Martin S. Mascarinas, Jr. were college acquaintances whose dating relationship evolved into cohabitation and then marriage following an unplanned pregnancy. While living together before marriage and after solemnization, Marie alleged escalating physical and emotional abuse by Martin: controlling conduct, forced completion of his schoolwork by Marie, deletion of her friends’ contacts, drunkenness with nonconsensual intercourse leading to pregnancy, physical assaults (including an incident that caused miscarriage), repeated infidelities, and financial domination. Martin did not contest service and failed to file an answer at trial.
Marie filed a petition to declare the marriage null under Article 36 of the Family Code (Civil Case No. R-PSY-16-21858-CV) on February 19, 2016, alleging psychological incapacity. At trial in Branch 109, RTC Pasay City, Marie testified and presented lay testimony from Felicito Rocky Vargas and expert testimony from clinical psychologist Regina V. Beltran, who prepared a Psychological Evaluation Report diagnosing Martin with narcissistic personality disorder co-existing with antisocial and dependent personality disorder; she administered multiple psychological instruments (Revised Beta Examination II, Bender Visual Motor Gestalt Test, Machover Draw a Person Test, Rorschach, Manchester Personality Questionnaire, Curtis Completion Form, Self-Analysis Test) and relied on interviews with Marie and a collateral informant.
The RTC (Presiding Judge Tingaraan U. Guiling) rendered a decision on August 17, 2017, declaring the marriage null for psychological incapacity, finding gravity, juridical antecedence and incurability established and giving weight to Beltran’s report. The Office of the Solicitor General (for the Republic) moved for reconsideration and, after denial by the RTC, appealed to the Court of Appeals via a notice of appeal.
The Court of Appeals (Special Seventeenth Division) reversed on December 6, 2019 (CA-G.R. CV No. 112231), concluding the totality of petitioner’s evidence was insufficient to prove psychological incapacity; it discounted Beltran’s report for lack of required depth and independent corroboration and found th...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in discounting the probative value of the psychologist’s evaluation and related expert testimony for lack of independent corroboration and depth?
- Did petitioner prove, by clear and convincing evidence, that respondent Martin was psychologically incapacitated — in the senses of gravity, juridical antecedence, and incurability — under Article 36 of the Family Code, such that th...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)