Case Digest (G.R. No. L-14457)
Facts:
John Arnel H. Amata filed a petition for declaration of nullity of his marriage to Haydee N. Amata on October 13, 2008 alleging psychological incapacity; the Regional Trial Court of Imus, Cavite, Branch 20 declared the marriage void ab initio in a July 20, 2011 Decision. The Office of the Solicitor General appealed; the Court of Appeals affirmed in a May 29, 2014 Decision, and the Republic of the Philippines filed a petition for review on certiorari to the Supreme Court.
Issues:
- Was the Office of the Solicitor General's Motion for Extension under Section 2, Rule 45, Rules of Court properly grantable?
- Was there sufficient evidence to annul the marriage for psychological incapacity under Article 36 of the Family Code?
Ruling:
The Court granted the OSG's motion for extension and accepted the petition for review as timely filed. On the merits, the Court reversed the Court of Appeals and set aside the RTC judgment, and dismissed the petition for declaration of nullity for lack of merit.
Ratio:
The Court found the extension under Section 2, Rule 45 permissible where the OSG timely filed a motion showing justifiable reasons and no intent to delay. On Article 36, applying the standards in recent jurisprudence (including the Tan-Andal refinements), the petitioner failed to prove by clear and convincing evidence the requisite elements of psychological incapacity—gravity, juridical antecedence, and legal incurability—because the RTC relied mainly on the respondent's affidavit and a noncomprehensive expert report without identifying a natal or supervening disabling root cause that existed at the time of marriage and rendered him incapable of essential marital obligations; the evidence showed merely an unsatisfactory marriage or refusal to cohabit, which does not satisfy Article 36.
Doctrine:
- Section 2, Rule 45, Rules of Court allows a single extension of thirty days for filing a petition for review on certiorari for justifiable reasons if timely moved and fees deposited.
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