G.R. No. 108854 - Krohn vs. Court of Appeals

Edgar Krohn, Jr., and Ma. Paz Fernandez were married on 14 June 1964 at Saint Vincent de Paul Church, Manila, and had three children: Edgar Johannes, Karl Wilhelm, and Alexandra.
Marital relations became strained; in 1971 Ma. Paz underwent psychological testing to relieve marital tensions, but the effort failed, leading to an actual separation in 1973.

In 1975, Edgar obtained a confidential psychiatric evaluation report prepared by Drs. Cornelio Banaag, Jr., and Baltazar Reyes, which he presented in a 2 November 1978 petition before the Tribunal Metropolitanum Matrimoniale in Manila.
The tribunal nullified their church marriage on the ground of incapacity to assume marital obligations (“incapacitas assumendi onera conjugalia”), the decree being confirmed final and definite on 10 July 1979.
On 30 July 1982, the Pasig CFI (now RTC Pasig, Br. II) granted the voluntary dissolution of their conjugal partnership.

On 23 October 1990, Edgar filed a petition for annulment of marriage in the RTC of Makati, Br. 144, again invoking the confidential psychiatric evaluation report.
Ma. Paz, in her Answer, merely denied the report as “unfounded or irrelevant” and later filed a Manifestation and a “Statement for the Record” asserting her objection to disclosure under the physician-patient privilege and contesting the ground of psychological incapacity.
At the 8 May 1991 hearing, Edgar testified on the report’s contents; Ma. Paz objected on privileged-communication grounds. The trial court overruled the objection and admitted the report, reasoning that Edgar was not a physician and Ma. Paz had not timely invoked the privilege.
Ma. Paz’s motions to reconsider and to reinstate her Statement for the Record were denied. She then petitioned the Court of Appeals, which dismissed her certiorari petition on 30 October 1992, and denied reconsideration on 5 February 1993. Ma. Paz thereafter sought review via certiorari before the Supreme Court.

Whether the physician-patient privilege (Rule 130, Sec. 24(c), Rules of Court) bars Edgar Krohn, Jr. (a non-physician), from testifying to and submitting a confidential psychiatric evaluation report prepared by Ma. Paz’s physicians.
Whether Ma. Paz’s “Statement for the Record” should have been admitted into evidence or properly struck from the record for lack of compliance with procedural and evidentiary rules.