G.R. No. 246868 - Republic vs. Claur

Angelique Pearl O. Claur filed a petition for declaration of nullity of her marriage with Mark A. Claur on the ground of psychological incapacity.
Mark A. Claur did not file an answer despite notice.
The Office of the Solicitor General (OSG), representing the Republic, opposed the petition and filed a petition for review after the Court of Appeals affirmed the nullity.

Angelique Pearl and Mark were high school classmates; Angelique was attracted to Mark despite his flirtatious and drinking habits.
Their relationship was characterized by jealousy, mistrust, repeated breakups, and reconciliations—about twenty times over five years.
Angelique Pearl became pregnant unexpectedly at age 20; Mark was 21. Despite hesitation, they married on January 3, 2009, partly due to pressure from Mark and his parents.
After marriage, Angelique Pearl experienced difficulties living with Mark's parents and uncovered Mark’s lies about his education and family’s financial status.
Mark was unemployed, irresponsible, extravagant, and dependent on Angelique Pearl financially.
The couple’s relationship was marred by violence and quarrels; Mark physically abused Angelique Pearl, including an incident where he broke her jaw.
They separated several times, and Mark abandoned the family on multiple occasions.

Johnson C. Tiu, Angelique Pearl's uncle and confidant, testified about the couple's volatile relationship and Mark’s abusive behavior.
Dr. Jay Madelon Castillo-Carcereny, psychiatrist, personally examined Angelique Pearl and interviewed her father. She diagnosed Angelique Pearl with borderline personality disorder and Mark with narcissistic personality disorder based on interviews and psychological tests (including Culture Fair Test, Basic Personality Inventory, House-Tree-Person, Draw-A-Person, Bender Gestalt Visual Motor Test, Luscher Full Color Test, and Zung Depression Scale).
Dr. Castillo-Carcereny found the disorders to be grave, permanent, and incurable, rooted in dysfunctional family backgrounds.
She recommended the marriage be declared void due to both parties' psychological incapacity.

The Regional Trial Court granted the petition declaring the marriage void on November 26, 2015, citing psychological incapacity of both parties.
The OSG filed a motion for reconsideration, which was denied.
The Court of Appeals, through a Decision dated January 30, 2018, affirmed the trial court’s ruling based on the totality of evidence and expert findings, later denying OSG’s motion for reconsideration.
The Republic filed a petition for review before the Supreme Court, arguing the absence of sufficient evidence for psychological incapacity and challenging the credibility of testimonies and expert findings.
Angelique Pearl maintained that the evidence sufficiently proved their psychological incapacity as per Article 36 of the Family Code.

Whether the evidence on record sufficiently established the psychological incapacity of both spouses to justify the declaration of nullity of their marriage under Article 36 of the Family Code.
Whether the diagnosis and testimony of the psychiatrist, which partly relied on hearsay, could be credited in the absence of a personal examination of Mark.