G.R. No. L-24968 - Saura Import and Export Co., Inc. vs. Development Bank of the Philippines

Petitioner Rowena Manlutac-Green and respondent Jeffery A. Green started dating after meeting in 2006 in Angeles City, Pampanga.
At the time, Rowena had two children from a previous relationship; Jeffery was married with a pending divorce.
Rowena gave birth to a third child, Abigail, on August 22, 2008; Jeffery acknowledged paternity.
They married on May 8, 2010, at St. Ignatius de Loyola Cathedral in Quezon City.
After marriage, Jeffery worked and stayed mostly in Makati City; Rowena split time between Jeffery and her children.

On July 7, 2014, Jeffery filed for nullity of marriage citing both parties’ psychological incapacity under Article 36 of the Family Code.
Attached documentary evidence included proof of Rowena's infidelity, lies, debts, and a Psychiatric Evaluation Report by Dr. Ma. Bernadette Manalo-Arcena.
The psychiatric evaluation was based on interviews with Jeffery, Rowena, Rowena’s mother, and a mutual friend.
Evidence detailed Rowena’s debts (~₱4 million), use of abortifacient medication, pathological gambling, falsified documents, infidelity, and lying about Abigail's paternity.

Rowena was served summons but did not file an answer or pre-trial brief.
The Office of the City Prosecutor found no evidence of collusion between parties.
In a June 5, 2017 Decision, the Regional Trial Court (RTC) declared the marriage null and void ab initio due to Rowena’s psychological incapacity.
The RTC found Rowena’s psychological conditions—Borderline Personality Disorder and Antisocial Personality Disorder—supported by the evidence.
The RTC denied Rowena’s motion for reconsideration on August 11, 2017.

Rowena appealed; the Court of Appeals (CA) affirmed the RTC decision in a June 30, 2020 Decision.
The CA concluded that Rowena had psychological incapacity at the time of marriage affecting her essential marital obligations.
The CA upheld that the root cause, gravity, and incurability of Rowena’s psychological incapacity were established.
The CA denied Rowena’s motion for reconsideration on January 29, 2021.

Rowena petitioned for review, contesting factual findings and weight given to expert testimony.
She challenged the credibility of Dr. Manalo-Arcena’s evaluation and argued her debts and living arrangements do not prove incapacity.
Respondents countered asserting that clear and convincing evidence supported the psychological incapacity ground.

Whether the petitioner, Rowena Manlutac-Green, was psychologically incapacitated to comply with her essential marital obligations under Article 36 of the Family Code at the time of marriage, thus justifying the declaration of nullity.