Case Digest (G.R. No. 209278)
Facts:
Irene Constantino Datu v. Alfredo Fabian Datu, G.R. No. 209278, September 15, 2021, Third Division, Leonen, J., writing for the Court. Petitioner Irene Constantino Datu (wife) sought review of the Court of Appeals’ decision affirming the Regional Trial Court’s declaration that her marriage to respondent Alfredo Fabian Datu (husband) was void for psychological incapacity.The spouses married on December 15, 1980 and had two children. On January 3, 2005, Alfredo filed a Complaint in the Regional Trial Court (RTC) of Olongapo City for declaration of nullity of marriage due to psychological incapacity. The City Prosecutor, deputized to appear for the Republic, filed a manifestation that “no evidence of collusion exists.” Irene filed an Answer (amended July 5, 2006) and the case proceeded to trial.
At trial Alfredo testified that he had been discharged from the United States Navy after psychiatric and medical evaluations showed schizophrenia; he described delusions (believing himself an emissary of God who could have multiple wives), refusal to work because of divine command, and eventual separation from Irene. Alfredo introduced a medical certificate (Dr. Jose Rommel T. Soriano), written findings from the U.S. Veterans Affairs Office, and the expert report and testimony of clinical psychologist Martha Johanna D. Dela Cruz, who diagnosed paranoid schizophrenia and opined the condition was enduring and incurable. Alfredo’s aunt corroborated aspects of his behavior and beliefs.
Irene testified she separated because Alfredo found another woman, that the spouses had an agreement for support which Alfredo later breached, and that she received a $400 VA benefit as Alfredo’s legal wife; she declined psychological evaluation by Dela Cruz and later admitted that the VA pension was because of her husband’s schizophrenia. The RTC (Sept. 25, 2007) found Alfredo psychologically incapacitated, declared the marriage null and void, and ordered that Alfredo continue providing support to the children. Irene’s motion for new trial alleging collusion, fraud and counsel’s conflict of interest was denied (Dec. 27, 2007).
The Court of Appeals (Thirteenth Division; Associate Justice Michael P. Elbinias penned the decision) affirmed the RTC in its September 28, 2012 Decis...(Pro-only)
Issues:
- Were the trial proceedings tainted by extrinsic fraud, collusion, or counsel’s conflict of interest so as to invalidate the RTC’s judgment?
- Did respondent Alfredo Fabian Datu in fact suffer from schizophrenia such that the factual findings below should be disturbed?
- Were the elements of psychological incapacity under Article 36 of the Family Code—gravity, juridical antecedence, and incurability—prov...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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