Case Digest (G.R. No. 248254)
Facts:
- Beverly A. Quilpan (petitioner) and Johnny R. Quilpan (respondent) met in Claveria, Cagayan, in 1985.
- Johnny, a fisherman, courted Beverly, and they began living together in 1986.
- They married on December 26, 1987, and had two children, Stephen and Sheena.
- Beverly discovered Johnny's gambling, jealousy, and womanizing tendencies, including fathering a child with another woman in 1980.
- Despite this, Beverly stayed in the marriage, even taking out a loan to buy Johnny a motor banca to augment his income.
- In 1993, Beverly left for Hong Kong to work as a domestic helper, remitting her earnings to support Johnny and their children.
- Johnny neglected his responsibilities, engaged in extramarital affairs, and sold his wedding ring to support his vices.
- In 1994, Johnny disappeared, and Beverly assumed he was dead.
- Beverly single-handedly raised their children and bought a parcel of land in Quezon City in 2003.
- Johnny reappeared in 2007, revealing he had fathered five children with another woman, Prem Rose Cacho Dilao, and married her in 2004.
- Beverly filed a petition to nullify their marriage in 2008 but could not locate the psychiatrist who initially evaluated Johnny.
- She filed another petition in 2016, supported by a psychiatric evaluation from Dr. Valentina del Fonso Garcia, who diagnosed Johnny with anti-social, narcissistic personality disorder with paranoid features.
- The Regional Trial Court (RTC) dismissed Beverly's petition but declared her the exclusive owner of the properties she acquired.
- Beverly appealed to the Court of Appeals (CA), which also dismissed her appeal.
- Beverly then filed a petition for review with the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court granted Beverly's petition for review.
- The Court reversed and set aside the CA's Decision dated February 28, 2019, and Resolution dated July 2, 2019.
- The marri...(Unlock)
Ratio:
- The Supreme Court referenced its recent pronouncement in Tan-Andal v. Andal.
- A spouse can be declared psychologically incapacitated under Article 36 of the Family Code if clear and convincing evidence shows that, at the time of the marriage, the spouse genuinely lacked an understanding of essential marital obligations.
- This incapacity does not require a personality disorder but a psychic caus...continue reading
Case Digest (G.R. No. 248254)
Facts:
Beverly A. Quilpan (petitioner) and Johnny R. Quilpan (respondent) met in Claveria, Cagayan, in 1985. Johnny, a fisherman, courted Beverly, and they began living together in 1986. They married on December 26, 1987, and had two children, Stephen and Sheena. Beverly later discovered Johnny's gambling, jealousy, and womanizing tendencies, including fathering a child with another woman in 1980. Despite this, Beverly stayed in the marriage, even taking out a loan to buy Johnny a motor banca to augment his income. In 1993, Beverly left for Hong Kong to work as a domestic helper, remitting her earnings to support Johnny and their children. Johnny, however, neglected his responsibilities, engaged in extramarital affairs, and sold his wedding ring to support his vices. In 1994, Johnny disappeared, and Beverly assumed he was dead. She single-handedly raised their children and bought a parcel of land in Quezon City in 2003. Johnny reappeared in 2007, revealing he had fathered five children with another woman, Prem Rose Cacho Dilao, and married her in 2004. Beverly filed a petition to nullify their marriage in 2008 but could not locate the psychiatrist who initially evaluated Johnny. She filed another petition in 2016, supported by a psychiatric evaluation from Dr. Valentina del Fonso Garcia, who diagnosed Johnny with anti-social, narcissistic personality disorder wit...