G.R. No. 250618 - Dedicatoria vs. Dedicatoria

Jennifer A. Dedicatoria and Ferdinand M. Dedicatoria were married on December 20, 1995.
On October 23, 2014, Jennifer filed a Petition for Declaration of Nullity of Marriage on the ground of Ferdinand’s alleged psychological incapacity.

Jennifer testified about Ferdinand’s irresponsible, immature, insensitive, and self-centered behavior.
She recounted instances of living arrangements where Ferdinand resided with his parents while expecting her to cater to his family’s needs.
Circumstances included disagreements over household responsibilities and Ferdinand’s consistent preference for his parents’ home over their own residence.
Jennifer further alleged that after her pregnancy and the birth of their child, Ferdinand continued his pattern of neglect, eventually leading to estrangement and the revelation of his cohabitation with another woman.

Jennifer’s account was corroborated by Anarose Talag-Aguirre, a long-time friend who testified about the breakdown of the marital relationship and observed Ferdinand’s dependence.
Anarose characterized Ferdinand as immature and a “mama’s boy,” reinforcing the claims of his inability to perform marital obligations.
No countervailing evidence or testimony was presented to challenge these accounts.

Clinical psychologist Dr. Sheila Marie O. Montefalcon conducted psychological tests and interviews with Jennifer, Ferdinand’s sister Teresita Dedicatoria, and Anarose.
Montefalcon diagnosed Ferdinand with Dependent Personality Disorder, noting characteristics of chronic dependency, immaturity, and an inability to assume marital responsibilities.
The clinical evaluation emphasized that the disorder is grave, deeply rooted from childhood experiences, and incurable in the legal sense, affecting his capacity to engage in essential marital obligations.

The Regional Trial Court (RTC) of Pasay City, Branch 109, declared the marriage null and void under Article 36 of the Family Code based on the totality of evidence regarding Ferdinand’s psychological incapacity.
The RTC’s decision was subsequently challenged, leading to a reversal by the Court of Appeals (CA) on May 31, 2019, which held that the evidence was insufficient as it merely described negative traits without establishing requisite elements such as juridical antecedence, gravity, and incurability.
Jennifer’s petition for reconsideration was denied by the CA in a subsequent resolution dated November 26, 2019.
The case was elevated to the Supreme Court through a Petition for Review on Certiorari under Rule 45, raising issues on the proper evaluation of psychological incapacity evidence.

Whether the totality of clear and convincing evidence presented was sufficient to establish Ferdinand’s psychological incapacity as required under Article 36 of the Family Code.
Whether the evidence demonstrating psychological incapacity must strictly conform to clinical or medical parameters, or if a legal interpretation based on behavior and personality traits is acceptable.

Whether the testimonies of Jennifer, Anarose, and the clinical evaluation by Dr. Montefalcon, despite the absence of Ferdinand’s personal examination, sufficiently prove a psychological incapacity existent at the time of the marriage.
Whether the alleged self-serving nature of Jennifer’s testimony and the reliance on collateral testimonies from persons close to the parties affect the evidence’s probative value.

Whether Ferdinand’s psychological attributes, as evidenced by his dependency and immaturity, meet the legal requirements of juridical antecedence, gravity, and incurability in order to void the marriage.