G.R. No. 228127 - Clavecilla vs. Clavecilla

Fernando C. Clavecilla (petitioner) met Marivic V. Clavecilla in December 1986 while he was posted as finance officer in Saudi Arabia and she was a nurse in Jeddah.
They courted, engaged late 1987, and married on December 10, 1987 at the Philippine Consulate in Jeddah; a second ceremony was held on March 12, 1988 in Manila.
They had one son, Patrick Joshua, born September 21, 1993.

On November 14, 2006, petitioner filed for annulment under Art. 36 of the Family Code, alleging Marivic’s psychological incapacity—carefree, nagging, demanding, unwilling to work, and incurring secret debts.
Psychologist Nedy Tayag diagnosed petitioner with Narcissistic Personality Disorder (NPD), opining his incapacity to fulfill marital obligations, supported by interviews of petitioner’s friends.
Marivic denied the allegations, countered that petitioner was the one psychologically incapacitated—selfish, irresponsible, unfaithful, and financially neglectful.

RTC (Apr. 10, 2013) granted annulment based on petitioner’s NPD, finding juridical antecedence, gravity, and incurability; ordered dissolution of property relations, reinstatement of child support, and custody provisions.
CA (June 30, 2016 Decision; Oct. 7, 2016 Resolution) reversed: held petitioner failed to prove root cause, gravity, and incurability of psychological incapacity for either spouse; marriage remains valid.

Whether the petition is defective for lack of petitioner’s personal verification and certification against forum shopping.
Whether factual issues may be raised in a Rule 45 petition for certiorari.

Whether a psychologically incapacitated spouse may initiate an Art. 36 nullity petition.
Whether Kalaw v. Fernandez relaxed or abandoned the Molina guidelines for psychological incapacity.
Whether petitioner or respondent established psychological incapacity warranting annulment.