Case Digest (G.R. No. 176579)
Facts:
Petitioner Rowena Manlutac-Green sought relief from this Court after the Court of Appeals affirmed the Regional Trial Court of Makati City’s June 5, 2017 decision declaring her marriage to Jeffery A. Green (solemnized May 8, 2010 in Quezon City) void ab initio for petitioner’s psychological incapacity under Article 36 of the Family Code; the petition for declaration of nullity was filed by respondent on July 7, 2014, the Court of Appeals affirmed on June 30, 2020, and denied reconsideration on January 29, 2021.
The RTC credited a Psychiatric Evaluation by Dr. Ma. Bernadette Manalo-Arcena based on interviews of the spouses, petitioner’s mother, and a mutual friend, and documentary evidence (collection cases, DNA result, photographs) and found petitioner suffered Borderline and Antisocial personality traits whose gravity, juridical antecedence, and incurability rendered her incapable of performing essential marital obligations.
Issues:
- Whether Rowena Manlutac-Green was psychologically incapacitated to comply with her essential marital obligations under Article 36 of the Family Code at the time of the marriage.
Ruling:
The Court denied the Petition and affirmed the Court of Appeals’ June 30, 2020 Decision and January 29, 2021 Resolution. The Court held that respondent proved by clear and convincing evidence that petitioner was psychologically incapacitated such that the marriage was null and void ab initio.
Ratio:
Applying the guiding principles of Tan-Andal v. Andal and related authorities, the Court construed psychological incapacity as a durable aspect of a spouse’s personality structure that manifests in clear acts of dysfunctionality undermining the marriage, and requires proof of gravity, juridical antecedence, and legal incurability. The Court gave probative weight to the Psychiatric Evaluation—derived from interviews with the parties and independent witnesses—and to documentary evidence (DNA test, collection cases, photographs), finding the totality of evidence established the requisite elements of psychological incapacity by clear and convincing proof.
Doctrine:
- Article 36 of the Family Code requires psychological incapacity characterized by gravity, juridical antecedence, and legal incurability.
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