Dedicatoria vs. Dedicatoria

Facts:

Jennifer A. Dedicatoria (petitioner) and Ferdinand M. Dedicatoria were married on December 20, 1995. On October 23, 2014 Jennifer filed a Petition for Declaration of Nullity of Marriage under Article 36 of the Family Code, alleging Ferdinand’s psychological incapacity. Summons was effected via substituted service and Ferdinand did not file an answer. The Office of the Solicitor General appeared for the Republic and deputized the Office of the City Prosecutor of Pasay City; the prosecutor found no collusion between the parties.

At trial Jennifer testified to a longstanding pattern of Ferdinand’s dependency on his parents, immaturity, failure to assume marital and parental duties, habitual residence with in‑laws, absence of work, and eventual cohabitation with another woman who bore him a child. She left with their son in 1999 and the couple lived separately thereafter. Jennifer presented Dr. Sheila Marie O. Montefalcon, a clinical psychologist, who conducted psychological testing and collateral interviews with Ferdinand’s sister, Teresita, and the couple’s friend Anarose Talag‑Aguirre; Ferdinand refused personal assessment. Montefalcon diagnosed Ferdinand with Dependent Personality Disorder and opined the condition was grave, juridically antecedent, and incurable in the legal sense. Anarose corroborated long‑term estrangement and Ferdinand’s neglect.

The Regional Trial Court (Pasay City, Branch 109) in a Decision dated November 23, 2015 declared the marriage void under Article 36, directing annotation of the marriage certificate; the RTC denied the Republic’s motion for reconsideration in an Order dated January 29, 2016. On appeal, the Court of Appeals, in a Decision dated May 31, 2019, reversed and dismissed the petition, finding insufficient proof of juridical antecedence, gravity, and incurability — criticizing the expert report as lacking permanence and noting absence of an independent pre‑marriage source; the CA denied reconsideration in a Resolution dated November 26, 2019. Jennifer filed this Petition for Review on Certiorari under Rule 45 seeking reinstatement of the RTC judgment and arguing the totality of evidence (...(Pro-only)

Issues:

• May the Supreme Court re‑examine the Court of Appeals’ factual findings in this Rule 45 petition?
• Whether the evidence presented suffices to prove Ferdinand’s psychological incapacity to render the marriage void under Article 36 of ...(Pro-only)

Ruling:

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Ratio:

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Doctrine:

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