Title
Go-Yu vs. Yu
Case
G.R. No. 230443
Decision Date
Apr 3, 2019
Marriage nullity petition denied; petitioner failed to prove psychological incapacity under Article 36, insufficient evidence, marriage upheld.
A

Case Digest (G.R. No. 230443)

Facts:

  • Parties and Case Origin
    • Petitioner Mary Christine C. Go-Yu filed a Petition for Declaration of Nullity of Marriage and Dissolution of the Absolute Community of Property against respondent Romeo A. Yu before the Regional Trial Court (RTC) of Davao City, Branch 12, on October 21, 2009.
    • Petitioner alleged that she suffered from Narcissistic Personality Disorder, a psychological incapacity existing prior to their marriage, which incapacitated her from performing essential marital obligations.
    • Respondent denied psychological incapacity and asserted that petitioner only had behavioral problems adjusting to marriage and respondent's relatives. He also challenged the claim regarding property subject to dissolution.
  • Marriage Background and Marital Issues
    • Petitioner, educated at University of British Columbia, became senior VP in the family business; met respondent casually through her mother, married on June 11, 1999.
    • Post-marriage, they lived in respondent’s family home, where petitioner faced mother-in-law’s intrusion; respondent promised to move but never did.
    • Petitioner’s social life shrunk; she managed household and finances alone as respondent focused on personal/social activities.
    • Sexual relations decreased greatly after marriage; petitioner was unable to conceive and respondent refused in vitro fertilization.
    • Petitioner was eventually diagnosed by psychiatric expert with Narcissistic Personality Disorder said to exist before marriage.
  • Trial Proceedings
    • Petitioner presented documentary and testimonial evidence, including from a psychiatrist, friend, and secretary.
    • After petitioner rested, respondent filed Demurrer to Evidence arguing insufficient proof of psychological incapacity.
    • RTC denied the demurrer on June 20, 2013, holding petitioner gave substantial evidence of personality disorder.
    • Respondent’s Motion for Reconsideration was denied on July 31, 2013.
  • Court of Appeals Proceedings
    • Respondent filed a Petition for Certiorari under Rule 65, questioning the RTC’s denial of Demurrer to Evidence and Motion for Reconsideration.
    • On January 13, 2017, CA reversed RTC's denial and granted the demurrer, dismissing petitioner’s nullity petition for lack of proof of psychological incapacity.
    • CA held that petitioner’s evidence was patently lacking, and the trial court gravely abused discretion in denying the demurrer.
    • Petitioner’s motion for reconsideration was denied by CA on March 6, 2017.
  • Present Petition for Review on Certiorari (Supreme Court)
    • Petitioner contests CA’s failure to consider subsequent evidence after demurrer, the sufficiency of her evidence, and timeliness of her motion for reconsideration.

Issues:

  • Whether the continuation of trial court proceedings and the presentation of respondent’s evidence moots or overtakes the CA’s grant of certiorari petition reversing the RTC’s denial of demurrer to evidence.
  • Whether petitioner sufficiently established psychological incapacity to justify declaration of nullity of marriage.
  • Whether the trial court gravely abused its discretion in denying respondent’s demurrer to evidence despite the supposed insufficiency of petitioner’s evidence.
  • Whether the CA erred in ruling on petitioner’s motion for reconsideration as filed out of time.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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