G.R. No. 256939 - Perez vs. JP Morgan Chase Bank N.A.

Reynaldo Navales and Nilda Navales met in 1986 in a local bar where Nilda was employed as a waitress.
Their relationship developed quickly, with Reynaldo financing Nilda’s studies and influencing her change in employment status as she began managing a boarding house.
Despite knowing that Nilda maintained communications with penpals and had an illegitimate child from an undisclosed man, Reynaldo proposed marriage to prevent her from marrying someone else, particularly an American suitor encouraged by her uncle.
They were married on December 29, 1988, before a Municipal Trial Court Judge in San Fernando, Cebu.

The initial period of the marriage was reportedly harmonious during the first year.
Reynaldo later alleged that difficulties arose when Nilda began to engage in business ventures (selling RTWs and cosmetics) which distracted her from fulfilling household duties.
Matters worsened when Nilda started working as an aerobics instructress at the YMCA, where Reynaldo claimed she exhibited flirtatious and promiscuous behavior:

Nilda was accused of wearing provocative attire.
She was said to have allowed male clients physical contact and introduced herself as single.
Reynaldo presented instances where she chose rides with other men or accepted kisses in his view, and her refusal to have a child was cited as further evidence of her alleged preoccupation with personal appearance.

On August 30, 1999, Reynaldo filed a Petition for Declaration of Absolute Nullity of Marriage and Damages before the RTC, Toledo City, asserting that Nilda’s alleged promiscuous behavior and concealed marital status revealed her psychological incapacity to fulfill marital obligations.
Reynaldo supported his claim by:

Presenting telephone directories showing Nilda’s use of her maiden name “Bacon”—a purported representation of being single.
Introducing witnesses such as Josefino Ramos and his cousin Violeta Abales who testified about Nilda’s behavior at the bar and the YMCA.
Relying on the expert opinion of Clinical Psychologist Leticia Vatanagul, who, in her March 28, 2001 assessment, diagnosed Nilda with several personality disorders including nymphomania, borderline personality, and anti-social personality disorder.

Asserting that Reynaldo was aware of her prior child and that he himself had extramarital affiliations.
Providing evidence such as a certification from the YMCA and a statement of accounts from PLDT, which confirmed her usage of her married name.

The RTC rendered its decision on January 2, 2002, declaring the marriage null on the basis of Nilda’s psychological incapacity, a ruling affirmed later by the Court of Appeals.
Nilda’s subsequent motions and arguments emphasized that:

The alleged psychological incapacity did not exist at the time of marriage.
Psychological incapacity, even if present, was neither permanent nor incurable.
The expert evidence was insufficiently specific and failed to corroborate claims of sexual impropriety beyond oral allegations.

Reynaldo, however, maintained that the totality of evidence established Nilda’s incapacity and that all proper procedural and evidentiary requirements (including state participation per Article 48) had been met, despite noted deficiencies in the State’s active involvement.

After the RTC’s decision and subsequent denial of a Motion for Reconsideration by Nilda, the Court of Appeals dismissed her appeal, reaffirming the RTC’s findings based on evidence including the telephone listings and expert testimony.
Reynaldo then pursued a Petition for Review on Certiorari, alleging grave abuse of discretion by the lower courts, improper findings contrary to the guidelines set in previous cases such as Republic of the Philippines v. Molina, and asserting that the factual findings of the trial were binding.
The pivotal issue before the Supreme Court became whether the evidentiary record sufficiently established Nilda’s psychological incapacity, thereby justifying the nullity of the marriage.

Whether the evidence presented by Reynaldo, including witness testimonies and expert psychological assessment, was sufficient to establish Nilda’s psychological incapacity to comply with her marital obligations under Article 36 of the Family Code.
Whether the psychological incapacity claimed by Reynaldo was a grave, permanent, and incurable condition that existed at or prior to the time of the marriage.
Whether the procedural requirements and evidentiary standards (including state participation as mandated by Article 48) were complied with in the proceedings for the declaration of nullity of marriage.
Whether the lower courts erred in concluding that Nilda’s actions—such as using her maiden name and exhibiting alleged flirtatious behavior—amounted to evidence of psychological incapacity.