G.R. No. 257136 - Domingo vs. Office of the Deputy Ombudsman for Military and Other Law Enforcement Offices

The parties, Rahnill Buhian Zamora (petitioner) and Lourdes Magsalay-Zamora (respondent), grew up in Isabel, Leyte and were schoolmates from kindergarten through high school.
Their friendship evolved into a romantic relationship during their high school years but later cooled when they attended different colleges and cities.
They reconnected in 2002 in the UAE when Rahnill was reviewing for his nursing board examinations and later started a romantic relationship again after Rahnill relocated to Abu Dhabi to work at a government hospital.

Influenced by Lourdes’s father, the couple married in a civil ceremony in Abu Dhabi on February 14, 2006.
In December 2006, their daughter, Shameika, was born.
Early in the marriage, Rahnill began alleging that Lourdes was “irresponsible and lacked support” as both a wife and a mother, citing instances of neglect and preferential treatment towards her own friends and family.

An episode where Lourdes reprimanded him for a minor domestic issue despite his efforts in caring for their child.
A conflict involving his sister, resulting in a confrontation that contributed to the breakdown of their cohabitation.

Lourdes eventually left Abu Dhabi for the Philippines with their daughter, Shameika, and later returned to the UAE leaving the child in the care of her maternal grandparents.
Although the couple reconciled and resumed living together, recurring issues persisted such as Lourdes’s aloof behavior, a refusal to share domestic responsibilities, and continued familial strife.

Rahnill sought a psychological evaluation, and a clinical psychologist (Maryjun Delgado) was commissioned to assess the marital relationship.
Delgado’s assessment, presented through a judicial affidavit, identified that Lourdes exhibited comorbid symptoms of Borderline Personality Disorder (BPD) and Narcissistic Personality Disorder (NPD).
The expert report detailed that:

Lourdes’s personality issues were grave, incurable, and had clear juridical antecedence predating the marriage, although the overt symptoms only manifested after the wedding.
These symptoms rendered her incapable of fulfilling the essential marital obligations, such as mutual love, support, respect, and cohabitation.

On October 30, 2014, Rahnill filed a petition for the declaration of nullity of marriage under Article 36 of the Family Code, alleging psychological incapacity as grounded on the clinical findings.
In support of his petition, Rahnill introduced four witnesses: himself, his mother (Esara), their house help (Mary Cris), and the expert psychologist (Delgado) via her judicial affidavit.
During trial, although Lourdes admitted Delgado as an expert witness, the psychological assessment report accompanying her testimony was not formally offered as evidence.
Lourdes, in her Answer, denied the allegations and asserted that she had maintained a hospitable environment toward family members, also contesting Rahnill’s behavior as temperamental and aggressive.

The Regional Trial Court (RTC) dismissed the petition for nullity on January 24, 2020, reasoning that Rahnill “rested his case without the Psychological Assessment Report” being formally offered in evidence.
A motion for reconsideration was raised by Rahnill, but it was denied in a June 18, 2020 order.
Subsequently, Rahnill elevated the case before the Supreme Court through a Petition for Review on Certiorari under Rule 45 of the Rules of Court.

Whether the dismissal of Rahnill’s petition solely because the expert witness’s psychological assessment report was not formally offered in evidence constituted an error by the trial court.
Whether the judicial affidavit and direct testimony of the expert, identifying and summarizing the contents of the psychological assessment report, are sufficient to satisfy evidentiary requirements under Rule 132, Section 34 of the Rules of Court.

Whether the totality of the evidence presented, including witness testimonies and the expert’s findings, adequately establishes that Lourdes possessed a personality disorder severe enough to render her incapable of fulfilling essential marital obligations.
Whether the psychological incapacity, based on the manifestation of comorbid symptoms (BPD and NPD), meets the criteria of being grave, incurable, and having juridical antecedence as required by Article 36 of the Family Code.