Case Digest (G.R. No. 249250)
Facts:
In Jerik B. Estella vs. NiAa Monria Ava M. Perez (G.R. No. 249250, September 29, 2021), petitioner Jerik Estella, a recruitment officer in Cebu, met respondent NiAa Monria Ava Perez in 2006 at their workplace and began a romantic relationship despite her ongoing affair. In January 2008 Perez became pregnant; although she doubted Estella’s paternity and sought an abortion, she ultimately gave birth to their son on September 20, 2008. The couple married on October 10, 2010 at the Cebu International Convention Center, but soon their union deteriorated as Perez exhibited persistent psychological incapacity—displaying irresponsibility toward her husband and son, impulsivity, abandonment, intense mood swings, unchecked anger, and disinterest in marital duties. After repeated quarrels, nocturnal escapades, and emotional neglect, Perez moved out in January 2011. Estella consulted clinical psychologist Dr. Maryjun Delgado, who diagnosed respondent with Borderline Personality Disorder andCase Digest (G.R. No. 249250)
Facts:
- Petition and Procedural History
- On July 19, 2011, Jerik B. Estella filed Civil Case No. AV-1618 in RTC Branch 26, Argao, Cebu, seeking nullity of his marriage with NiAa Monria Ava Perez under Article 36 of the Family Code.
- The RTC granted the petition on September 7, 2015; on October 12, 2018, the Court of Appeals reversed; its August 13, 2019 resolution denied reconsideration.
- Parties’ Relationship History
- The parties met in 2006 at eTelecare Global Solutions, Cebu City; respondent became pregnant in January 2008; their son was born September 20, 2008.
- They married on October 10, 2010, at Cebu International Convention Center and began living separately in January 2011.
- Allegations of Psychological Incapacity
- Petitioner alleged respondent showed irresponsibility, irritability, neglect of their child (e.g., failing to attend to feverish infant), jealousy, prioritizing friends, sudden emotional outbursts, and abandonment.
- Clinical psychologist Dr. Maryjun Delgado diagnosed respondent with Borderline Personality Disorder and Narcissistic Personality Disorder based on interviews with petitioner and his cousins; respondent refused examination.
- Respondent’s Defense
- Respondent denied neglect, illicit affair, and excessive social life; attributed marital discord to petitioner’s over-dependence on his parents.
- She declined psychological evaluation and submitted a bare denial in her Answer.
Issues:
- Main Issue
- Whether the Court of Appeals erred in reversing the Regional Trial Court’s nullity decree by finding that respondent’s psychological incapacity under Article 36 was not proven.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)