Case Digest (G.R. No. 165424)
Facts:
- Marriage: Lester Benjamin S. Halili and Chona M. Santos-Halili married on July 4, 1995, at the City Hall of Manila.
- Ages: Lester was 21 years old, and Chona was 19 years old at the time of marriage.
- Living Arrangements: They continued to live with their respective parents and never cohabited as husband and wife.
- Marital Issues: A year after their marriage, frequent arguments ensued, leading Lester to stop seeing Chona and start dating other women.
- Prank Calls: Lester received prank calls warning him to stop dating other women because he was already married.
- Petition: Lester filed a petition in the RTC of Pasig City, Branch 158, to have his marriage declared null and void on the grounds of psychological incapacity.
- Claims: Lester claimed he believed the wedding was a joke, the marriage certificate was fake, and they never lived together or consummated the marriage.
- RTC Decision: The RTC granted the petition, declaring Lester psychologically incapacitated to fulfill his essential marital obligations.
- CA Decision: On appeal, the CA reversed the RTC's decision, stating that the evidence presented by Lester failed to establish his psychological incapacity.
- Motion for Reconsideration: Lester's motion for reconsideration was denied, leading to this petition for review on certiorari under Rule 45 of the Rules of Court.
Issue:
- (Unlock)
Ruling:
- Petition Denied: The petition is denied.
- CA Decision Affirmed: The January 26, 2004 decision and September 24, 2004 resoluti...(Unlock)
Ratio:
- Burden of Proof: The Supreme Court held that Lester failed to meet the burden of proving the nullity of his marriage due to psychological incapacity.
- Evidence Presented: Lester's evidence included his own testimony and a psychological report by Dr. Natividad A. Dayan, Ph.D., diagnosing him with a mixed personality disorder.
- Psychological Report: Dr. Dayan's report indicated a dysfunctional family background, immaturity, and impulsive decision-making.
- Legal Standards: Psychological incapacity must be characterized by gravity, juridical antecedence, and incurability, as established in Republic v. CA and Molina.
- Insufficient Evidence: The evidence showed immaturity and difficulty in getting along with Chona, which did not m...continue reading
Case Digest (G.R. No. 165424)
Facts:
In the case of "Halili v. Santos-Halili," the petitioner, Lester Benjamin S. Halili, and the respondent, Chona M. Santos-Halili, were married on July 4, 1995, at the City Hall of Manila when they were 21 and 19 years old, respectively. Despite their marriage, they continued to live with their respective parents and never cohabited as husband and wife. A year after their marriage, the couple began to argue frequently, leading the petitioner to stop seeing the respondent and start dating other women. During this period, the petitioner received prank calls warning him to cease dating other women because he was already married. Consequently, Lester filed a petition in the Regional Trial Court (RTC) of Pasig City, Branch 158, seeking to have his marriage declared null and void on the grounds of psychological incapacity. He claimed that he believed the wedding was a joke and that the marriage certificate was fake. Furthermore, he emphasized that they never lived together or consummated the marriage. The RTC granted the petition, declaring Lester psychologically incapacitated to fulfill his essential marital obligations. However, on appeal, the Court of Appeals (CA) reversed the RTC's decision, stating that the evidence presente...