G.R. No. 213954 - Pugoy-Solidum vs. Republic

Hannamer C. Pugoy-Solidum and Grant C. Solidum were classmates during their fourth year in high school and eventually became sweethearts.
After graduation, Hannamer began working and eventually started living with Grant.
Initially, Grant’s family was favorably disposed toward Hannamer, appreciating her hardworking nature and role as the breadwinner of the family.

The relationship dynamics changed after Hannamer became pregnant, necessitating that she stop working.
Following the birth of their child, Hannamer’s mother influenced the couple to get married; she even assisted by moving in with them and financially supporting their living and wedding expenses.
Grant remained unemployed and did not contribute financially, relying solely on support from his older sibling and later on Hannamer’s family.

The marriage was solemnized on March 12, 2003, by Judge Albert S. Abragan of the RTC of Iligan City.
Hannamer personally spent funds for the wedding and their child’s baptismal expenses, reinforcing her financial burden in the family unit.

Tensions escalated when Hannamer’s mother moved in with the couple after quitting her job, leading to a souring of the relationship between Hannamer and Grant.
The marital issues culminated in Hannamer leaving their house to stay with Grant’s relatives, after which Grant ceased to visit or provide any financial support.
Eventually, Hannamer lost contact with Grant when she relocated with her child and mother to another town.

On January 3, 2010, Hannamer filed a petition for declaration of nullity of marriage under Article 36 of the Family Code, asserting that Grant was psychologically incapacitated to perform his essential marital obligations.
Hannamer alleged that Grant displayed a complete lack of understanding and responsibility as a husband and father, citing his absence in work and improper use of resources on gambling and cockfighting.
The petition was served on Grant via his uncle on February 2, 2011; however, Grant did not appear on the scheduled hearing.

During the trial, Hannamer testified on her own behalf regarding the marital history and Grant’s alleged incapacity.
Dr. Visitacion Revita testified and submitted both her judicial affidavit and psychological report, diagnosing Grant with narcissistic personality disorder with anti-social and dependent traits.

The report claimed that Grant’s disorder was grave, incurable, and stemmed from his childhood, influenced by a tolerant, dysfunctional, and permissive family environment.
Notably, Dr. Revita did not personally examine Grant but based her conclusions on Hannamer’s testimony and corroboration from Hannamer’s mother.

The Assistant Provincial Prosecutor also participated by filing a report amid Grant’s nonappearance, highlighting concerns about the possibility of collusion while ensuring evidence remained uncontrived.

The Regional Trial Court (RTC) of Tagaytay City, Branch 18, rendered a decision on June 29, 2011, declaring the marriage null and void ab initio on the ground of Grant’s psychological incapacity.

The judgment ordered the cancellation of the marriage contract from the Local Civil Registrar and the National Statistics Office.
Custody of the child was granted to Hannamer in the interest of the child’s welfare.

The Office of the Solicitor General (OSG) moved for reconsideration through an order dated August 26, 2011, which was denied by the RTC.
The OSG then appealed with the Court of Appeals (CA), arguing that Hannamer failed to prove the required elements of psychological incapacity and that the evidence, including Dr. Revita’s report, was unreliable and insufficient.

On March 31, 2014, the CA reversed the RTC’s ruling by dismissing the petition for nullity on the merits due to Hannamer’s failure to sufficiently prove that Grant’s psychological incapacity existed, was grave and incurable, and had its juridical antecedence.
The CA’s decision emphasized that the psychological report heavily depended on hearsay evidence and lacked corroborative factual data.
The appellate decision effectively maintained that the marriage between Hannamer and Grant remained valid.

Hannamer contended that the RTC had properly applied the Molina guidelines, asserting that personal psychological examination of the incapacitated spouse was not required if sufficient evidence was produced.
The OSG argued that the allegations only depicted marital discord (such as financial irresponsibility and mismatched expectations) rather than a legally cognizable state of psychological incapacity.
The Supreme Court, in reviewing the case, reaffirmed the criteria for psychological incapacity as needing to be grave, with juridical antecedence and legal incurability, and that the totality of evidence must meet these stringent requirements.

Whether the petitioner successfully proved that Grant suffered from a psychological incapacity that is grave, incurable, and existed prior to the marriage (juridical antecedence) as required under Article 36 of the Family Code.
Whether Dr. Revita’s psychological report and testimony, which were primarily based on information from the petitioner and her mother (without a personal examination of Grant), were sufficient to establish the psychological incapacity of Grant.
Whether the totality of the evidence, including the parties’ testimonies and other evidentiary material, sufficiently demonstrated that Grant’s alleged personality disorder incapacitated him from performing his essential marital obligations.
Whether the application of the Molina guidelines—followed by the RTC—was appropriate in the context of the evidence presented, given the subsequent interpretation and modifications introduced in Tan-Andal v. Andal.