Case Digest (G.R. No. 242362) Core Legal Reasoning Model
Facts:
Leonora O. Dela Cruz-Lanuza (Leonora) married Alfredo M. Lanuza, Jr. (Alfredo) in June 1984, and they had four children together. Leonora filed a Petition for Declaration of Nullity of Marriage with the Regional Trial Court (RTC) of Caloocan City in 2017 asserting that their marriage was void for lack of a valid marriage license and/or due to Alfonso's psychological incapacity. She testified that they did not secure or appear for a marriage license at the Local Civil Registry of Imus, Cavite. Initially harmonious, Alfredo's behavior deteriorated over time — he neglected his family duties, stayed out late, treated Leonora like a house occupant rather than a wife, and engaged in extramarital affairs. They separated in 1994, the year when Alfredo married another woman, Mary Ann Makalintal, in Quezon City. Alfredo subsequently married a third woman, Jane Alejo, evidenced by photos from a church wedding. Despite Leonora’s filing a bigamy complaint against Alfredo, the case w
Case Digest (G.R. No. 242362) Expanded Legal Reasoning Model
Facts:
- Marriage and Family Background
- Petitioner Leonora O. Dela Cruz-Lanuza married private respondent Alfredo M. Lanuza, Jr. in June 1984.
- They have four children together.
- Although the marriage contract states a marriage license from Imus, Cavite, Leonora did not secure or appear for any such license.
- Allegations and Marital Breakdown
- Initially smooth married life later deteriorated due to Alfredo's behavioral changes.
- Alfredo often came home late or early morning after nights out, neglected family duties, and did not provide financial support.
- Alfredo treated Leonora not as his wife but as an ordinary occupant of the house.
- Alfredo engaged in illicit affairs and married other women in 1994 and 2000.
- Leonora separated from Alfredo in 1994.
- A complaint for bigamy was filed but archived due to Alfredo's unavailability; he was dismissed from the police service after going AWOL.
- Psychological Evaluation and Evidence
- Based on legal advice, Leonora underwent a psychological evaluation by Clinical Psychologist Noel N. Ison.
- Ison interviewed Leonora, her sister, and daughter but could not assess Alfredo directly.
- Using collateral information, Ison diagnosed Alfredo with narcissistic personality disorder with borderline personality traits.
- Ison testified that such disorder renders an individual psychologically incapacitated to perform essential marital obligations.
- Trial Court Proceedings
- The Regional Trial Court dismissed the petition due to insufficient proof that Alfredo's subsequent marriages were valid and insufficient evidence of psychological incapacity.
- The court doubted the sufficiency and specificity of Ison's testimony.
- It ruled Alfredo's infidelity and behavior showed no durable psychological incapacity existing prior to marriage.
- The petition for nullity and the motion for reconsideration were denied.
- Court of Appeals Proceedings
- Leonora filed a Petition for Review under Rule 42; the Court of Appeals dismissed it as the wrong remedy, stating a Notice of Appeal was proper.
- The motion for reconsideration was denied due to procedural grounds and lack of demonstration of meritorious issue.
- Supreme Court Proceedings
- Leonora filed a Petition for Review on Certiorari before the Supreme Court.
- Alfredo failed to file comments or respond to Court orders.
- The Office of the Solicitor General defended the Court of Appeals' dismissal and contested sufficiency of evidence for psychological incapacity.
- The Office questioned the credibility of Ison's findings due to lack of personal examination of Alfredo.
Issues:
- Whether the Court of Appeals erred in dismissing Leonora's appeal on procedural grounds.
- Whether the evidence presented is sufficient to declare the marriage void for psychological incapacity.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)