G.R. No. 177960 - Dayap vs. Sendiong

Jordan Chan Paz and Jeanice Pavon Paz met in November 1996.
Jeanice was 19 years old while Jordan was 27 years old at the time of their meeting.
Their relationship progressed rapidly: they became a couple in January 1997, got engaged on 10 May 1997, had a civil wedding on 3 July 1997, and a church wedding on 21 September 1997.
The couple had one child, a son named Evan Gaubert, born on 12 February 1998.

After a serious altercation, Jeanice left the conjugal home on 23 February 1999.
On 15 September 1999, Jeanice filed a petition for the declaration of nullity of marriage on the ground of psychological incapacity.
Jeanice alleged that Jordan was psychologically incapable of assuming marital obligations due to:

An uncontrollable disposition toward self-preoccupation and self-indulgence.
A tendency to become violent and abusive when his desires were unmet.
Habitual lying about his whereabouts and consistently preferring the company of friends over family responsibilities.
An excessive attachment to his mother, for which he expected her to provide for their son’s needs, including asking for milk and diapers.

Jeanice also testified about escalating physical and verbal violence, including threats involving dangerous instruments (e.g., scissors and a golf club).
She asserted that Jordan failed to provide financial support and did not participate in raising their child after she left.

Psychologist Cristina R. Gates testified that Jordan suffered from Borderline Personality Disorder, citing symptoms such as impulsivity, delinquency, and instability.
Gates’ report suggested that Jordan’s disorder was grave, incurable, and had its roots in his family background—a condition purported to have existed before the marriage.
Jordan denied the allegations, accusing Jeanice of exaggeration and asserting that her claims reflected her personal insecurities and immaturity.
Jordan also challenged the admissibility and reliability of Gates’ psychological report, noting that:

He was not personally interviewed nor subjected to formal psychological testing by Gates.
Her diagnosis was derived solely from Jeanice’s statements and the transcript of her courtroom testimony, rendering it one-sided and hearsay.

On 13 May 2003, the Regional Trial Court (RTC) granted Jeanice’s petition, declaring the marriage void ab initio on the grounds that Jordan was psychologically incapacitated as defined under Article 36 of the Family Code.
The RTC emphasized that Jordan’s alleged Borderline Personality Disorder rendered him incapable of fulfilling his marital obligations under Articles 68 and 70 of the Family Code.
The RTC’s decision included provisions dissolving the absolute community of properties, determined custody arrangements (awarding custody of the minor to Jeanice), and set support responsibilities for the child.
Jordan filed a Notice of Appeal on 6 June 2003, which was approved by the trial court.
Subsequently, Jeanice filed a Motion to Dismiss the appeal on procedural grounds, specifically citing Jordan’s failure to file a motion for reconsideration within the prescribed period as mandated by Section 20 of A.M. No. 02-11-10-SC.
The Court of Appeals, in its resolutions dated 9 August 2004 and 26 November 2004, dismissed both Jordan’s appeal and his subsequent motion for reconsideration.
Later motions and resolutions were filed by both parties, which eventually led to the petition for review before the Supreme Court.

Whether Jordan Chan Paz was, at the time of the marriage and subsequently, psychologically incapacitated to comply with the essential obligations of marriage.
Whether the evidence presented, particularly the psychological testimony based on Jeanice’s statements, was sufficient to attribute to Jordan a grave, incurable personality disorder (specifically Borderline Personality Disorder) that would justify the nullity of the marriage.

The strict application of procedural rules regarding the filing of motions for reconsideration before an appeal is allowed.
Whether procedural lapses affected the merits of the case and the demonstration of psychological incapacity.