Case Digest (G.R. No. 209278)
Facts:
In IRENE CONSTANTINO DATU v. ALFREDO FABIAN DATU (G.R. No. 209278, September 15, 2021), petitioner Irene Constantino Datu and respondent Alfredo Fabian Datu were married on December 15, 1980 in Subic, Zambales, and had two children. On January 3, 2005, Alfredo filed before the Regional Trial Court (RTC) of Olongapo City a Complaint for declaration of nullity of marriage on the ground of psychological incapacity under Article 36 of the Family Code. The City Prosecutor manifested on September 6, 2005 that there was “no evidence of collusion” between the parties. Irene filed an Answer, later amended. Alfredo testified that in 1978 he joined the United States Navy but was discharged after 14 months for medical and psychiatric reasons, specifically schizophrenia. He met Irene after discharge, and they married following a premarital intimacy and his sister-in-law’s insistence. Alfredo described Irene’s sudden anger, materialism, nagging, and his own belief that he was God’s emissary,
Case Digest (G.R. No. 209278)
Facts:
- Marriage and Nullity Petition
- Irene Constantino Datu and Alfredo Fabian Datu married civilly on December 15, 1980 in Subic, Zambales, and had two children.
- On January 3, 2005, Alfredo filed before the Regional Trial Court (RTC) of Olongapo City a Complaint for declaration of nullity of marriage under Article 36 of the Family Code for psychological incapacity; the City Prosecutor manifested absence of collusion; Irene filed and amended her Answer.
- Evidence at Trial
- Alfredo’s Testimony and Documentary Evidence
- Discharged from the U.S. Navy after 14 months for psychiatric and medical reasons—diagnosed with schizophrenia (paranoid type).
- Belief that he is an emissary of God, refusal to work per divine command, left Irene, lives with another woman, no support arrangements beyond child pension.
- Aunt’s Testimony (Policornia Fabian)
- Corroborated Alfredo’s schizophrenia diagnosis and discharge.
- Described Irene as materialistic and jealous; recounted Alfredo’s spiritual messages.
- Expert Psychological Evaluation (Martha Johanna D. Dela Cruz)
- Diagnosed Alfredo with schizophrenia, paranoid type; found impaired judgment, incurable psychosis.
- Evaluated Irene’s refusal letter as indicative of shared psychotic disorder.
- Irene’s Testimony
- Former supervisor at Shakey’s Pizza, left work to manage family; separated due to Alfredo’s infidelity.
- Claimed a support agreement (60% of salary) breached by Alfredo; obtained $400 benefit from U.S. Veterans Affairs for Alfredo’s disability; admitted divergent religious beliefs and her children’s continued relationship with father.
- RTC Decision and Disposition
- Findings
- Alfredo’s psychological incapacity proven by three expert opinions, military and medical certificates, and his delusions preventing essential marital obligations (cohabitation, support, fidelity).
- Irene’s shared psychotic disorder found post-marriage—thus no juridical antecedence.
- Disposition
- Marriage declared null and void due to Alfredo’s psychological incapacity.
- Alfredo obliged to support the two children; visitation rights preserved.
- Appeals and Petition for Review
- Irene’s Motion for New Trial (claims of collusion, conflict of interest, fraud) denied by RTC.
- Court of Appeals affirmed RTC decision and resolution (Decision September 28, 2012; Resolution September 18, 2013), rejecting allegations of procedural irregularity.
- Irene filed a Petition for Review on Certiorari before the Supreme Court raising issues of schizophrenia diagnosis, elements of psychological incapacity, and alleged fraud in proceedings.
Issues:
- Whether respondent Alfredo Fabian Datu indeed suffered from schizophrenia.
- Whether all elements of psychological incapacity under Article 36 of the Family Code have been proven by Alfredo.
- Whether the trial proceedings were tainted by fraud, warranting reversal of the nullity decision.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)