Case Digest (G.R. No. 26284)
Facts:
Republic of the Philippines, G.R. No. 212717, March 11, 2020, First Division, Reyes, J., writing for the Court. The petition for review assails the Court of Appeals Decision dated September 9, 2013 and Resolution dated May 29, 2014 in CA‑G.R. CV No. 94407, which declared void the marriage between Ariel S. Calingo (petitioner in the RTC/CA proceedings) and Cynthia Marcellana‑Calingo (respondent in the RTC/CA proceedings).Ariel and Cynthia began living together in 1980 and had their church wedding on February 22, 1998; soon thereafter they separated (Ariel testified they stayed together about three years and have had virtually no contact for decades). Ariel filed a petition for declaration of nullity of marriage in the Regional Trial Court (RTC), alleging that Cynthia was psychologically incapacitated under Article 36 of the Family Code. Ariel presented his own testimony, lay witnesses (friends Francisca Bilason and Ruben Kalaw), and the psychological evaluation of Dr. Arnulfo Lopez, who diagnosed Cynthia with Borderline Personality Disorder with Histrionic Personality Disorder features and found Ariel to have an emotionally disturbed personality but not incapacitated.
On August 3, 2009 the RTC (Branch 107, Quezon City) denied Ariel’s petition for lack of sufficient proof that Cynthia’s traits were present at the inception of the marriage, grave, and incurable; the RTC’s August 3, 2009 Decision was followed by a denial of reconsideration on October 19, 2009. Ariel appealed to the Court of Appeals (CA). In a Decision dated September 9, 2013, the CA reversed the RTC, accepting Dr. Lopez’s diagnosis together with evidence of Cynthia’s quarrelsome behavior and alleged multiple extramarital affairs, and declared the marriage void ab initio. The CA’s resolution of May 29, 2014 pertained to post‑decision matters in CA‑G.R. CV No. 94407.
The Republic, through the Office of the Solicitor General (OSG), filed this Petition for Review (Rule 45) seeking reversal of the CA decision and defending the sanctity of marriage; the OSG argued that Ariel failed to prove psychological incapacity as required by Article 36 of ...(Subscriber-Only)
Issues:
- Whether the marriage of Ariel S. Calingo and Cynthia Marcellana‑Calingo should be declared void ab initio on the ground of psychological incapacity under Article 36 of the Fami...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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