G.R. No. 200544 - Ilocos Norte Electric Cooperative vs. Cynthia Gertrudes Andres-Ranjo, Elma Andres Maraaan, represented by William G. Maraaan

On September 7, 1975, Erlinda Matias, aged 16, married Avelino Parangan Dagdag, aged 20, at the Iglesia Filipina Independent Church in Cuyapo, Nueva Ecija.
The marriage certificate was issued by the Local Civil Registrar of Cuyapo, Nueva Ecija, on October 20, 1988.
Erlinda and Avelino had two children: Avelyn M. Dagdag (born January 16, 1978) and Eden M. Dagdag (born April 21, 1982), whose birth certificates were also issued on October 20, 1988.
The family lived in a house located in District 8, Cuyapo, Nueva Ecija, behind Avelino’s parents’ house.

One week after the wedding, Avelino began abandoning the family without explanation, disappearing for months at a time, then returning briefly before leaving again.
During his stays, Avelino was frequently intoxicated, engaging in drunken sprees with friends, and physically abusing Erlinda when she refused sexual intercourse.
In October 1993, Avelino left the family again and was not heard from thereafter.

Erlinda sought employment as a manicurist in Olongapo City to support herself and her children.
Erlinda learned that Avelino had been imprisoned for an unspecified crime and escaped from jail on October 22, 1985; a certification from Jail Warden Orlando S. Limon dated February 14, 1990, confirmed Avelino’s escape.
Avelino remains at-large to date.

On July 3, 1990, Erlinda filed a petition for judicial declaration of nullity of marriage on the ground of psychological incapacity under Article 36 of the Family Code before the Regional Trial Court (RTC) of Olongapo City.
Due to Avelino’s absence, summons was served by publication on September 3, 10, and 17, 1990 in a newspaper of general circulation.
During the hearing, Erlinda and her counsel appeared; only Erlinda and her sister-in-law Virginia Dagdag testified.
Virginia provided testimony that Avelino was frequently absent, quarreled often with Erlinda, and had abandoned the family for a prolonged period; she expressed pity for Erlinda and the children.
The trial court gave the investigating prosecutor until January 2, 1991, to manifest whether he would present controverting evidence. The prosecutor filed a manifestation indicating intention to intervene but did not submit evidence.

On December 27, 1990, the trial court declared the marriage null and void under Article 36 of the Family Code, despite the prosecutor’s intended intervention and before the deadline for the prosecutor’s manifestation.
The trial court ordered the Local Civil Registrar to record the nullity after the decision became final and executory.
The investigating prosecutor moved to set aside the judgment due to premature decision. The Solicitor General moved for reconsideration, arguing that psychological incapacity had not been proven.
The trial court denied the motions on August 21, 1991, ruling that prolonged abandonment, failure to support, physical abuse, and fugitive status constituted psychological incapacity manifesting as failure to comply with essential marital obligations.

The Solicitor General appealed on the sole ground that psychological incapacity under Article 36 was not proven.
On April 22, 1993, the Court of Appeals affirmed the RTC decision, describing Avelino as emotionally immature, irresponsible, an alcoholic, and a criminal whose continuous failure destroyed the integrity of the marriage.

The Solicitor General filed a petition for review, asserting that the psychological incapacity was not of the nature required by law, and that the Courts had erred in their interpretation and application.
The respondent argued that the evidence sufficiently established the psychological incapacity by preponderance of evidence.

Whether the trial court and the Court of Appeals correctly declared the marriage null and void under Article 36 of the Family Code on the ground of psychological incapacity.
Whether the psychological incapacity of Avelino Dagdag was proven to be medically or clinically existing at the time of marriage, permanent or incurable, and grave enough to incapacitate him from complying with essential marital obligations.
Whether the evidentiary requirements, including presentation of expert testimony and opportunity for the prosecution to present controverting evidence, were fulfilled.