Case Digest (G.R. No. 253342) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Petitioner Dionisio C. Laroco filed a petition for the declaration of nullity of his marriage with respondent Aurora B. Laroco based on Article 36 of the Family Code. They married on September 6, 1971, in Mankayan, Benguet. Prior to marriage, petitioner learned of respondent's alleged promiscuity and unfaithfulness. After their marriage, respondent was accused of infidelity, deceit in financial matters, and was even imprisoned for estafa. They separated in 1983 with their children living under petitioner’s custody. Petitioner underwent a psychiatric evaluation diagnosing both him and respondent with personality disorders leading to psychological incapacity to comply with essential marital obligations. The Regional Trial Court denied the petition for nullity, holding insufficient proof of psychological incapacity that predates the marriage. The Court of Appeals affirmed this decision. Petitioner filed a petition for review, asserting clear and convincing evidence of grave, incura... Case Digest (G.R. No. 253342) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Marriage
- Petitioner Dionisio C. Laroco met respondent Aurora B. Laroco in 1970 as students. They courted and became a couple, but petitioner broke up after learning respondent entertained other suitors.
- Petitioner's parents disapproved of respondent due to her reputation.
- Petitioner went to Manila to support respondent's mother undergoing cobalt therapy.
- Respondent became pregnant and insisted on marriage; her parents forced petitioner to marry her in Mankayan, Benguet, on September 6, 1971.
- They had three children born in 1972, 1973, and 1977.
- Marital Life and Conflicts
- Petitioner’s mother died in 1973; respondent moved to Baguio but stayed separately due to dislike from petitioner’s father.
- Respondent managed a canteen and continued to date other men, deceived petitioner, and incurred debts.
- Petitioner confronted respondent but was met with denial and lack of accountability.
- Respondent got arrested for estafa related to unpaid jewelry purchases; petitioner raised bail but respondent did not return home afterward.
- Respondent lived with her paramour; children later lived with petitioner due to maltreatment by paramour.
- Psychological Evaluation
- Petitioner consulted psychiatrist Dr. Clarette Rosario Dy who diagnosed petitioner with obsessive-compulsive personality disorder and respondent with histrionic personality disorder.
- Diagnoses highlighted traits such as perfectionism and rigidity for petitioner, and need for attention and superficial emotions for respondent.
- Dr. Dy concluded both spouses were psychologically incapacitated at the time of marriage with permanent and grave personality disorders, making them unfit for marital obligations.
- Trial and Appeal
- Petitioner filed a petition for nullity of marriage due to psychological incapacity under Article 36 of the Family Code.
- Respondent failed to file an answer.
- RTC denied the petition on grounds that evidence was insufficient to prove grave, incurable psychological incapacity.
- Court of Appeals affirmed the RTC decision, citing lack of sufficient proof and credibility issues in psychiatric report.
- Present Petition
- Petitioner sought review, arguing sufficient evidence proved grave and incurable psychological incapacity of both spouses pre-existing marriage.
Issues:
- Whether the marriage should be declared null and void on the ground of psychological incapacity under Article 36 of the Family Code.
- Whether the totality of evidence presented by petitioner proves grave, incurable psychological incapacity that existed at the time of marriage.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)