Case Digest (G.R. No. 171557) Core Legal Reasoning Model
Facts:
The case involves a petition for review on certiorari filed by the Republic of the Philippines against Rodolfo O. De Gracia, concerning the nullification of his marriage to Natividad N. Rosalem. The couple wed on February 15, 1969, at the Parish of St. Vincent Ferrer in Salug, Zamboanga del Norte. They resided in Dapaon, Sindangan, Zamboanga del Norte and had two children, Ma. Reynilda R. De Gracia and Ma. Rizza R. De Gracia. On December 28, 1998, Rodolfo initiated a verified complaint for declaration of nullity of marriage (Civil Case No. S-665) before the Regional Trial Court (RTC) of Zamboanga del Norte, claiming Natividad was psychologically incapacitated to fulfill her essential marital obligations.
The RTC, under an order dated January 5, 1999, directed a public prosecutor to investigate potential collusion, which ultimately concluded that there was none. During the trial on the merits, Rodolfo testified about the circumstances surrounding their marriage, indicating that
... Case Digest (G.R. No. 171557) Expanded Legal Reasoning Model
Facts:
- Marriage and Personal Background
- Rodolfo O. De Gracia and Natividad N. Rosalem were married on February 15, 1969 at the Parish of St. Vincent Ferrer in Salug, Zamboanga del Norte.
- The couple resided in Dapaon, Sindangan, Zamboanga del Norte and had two children: Ma. Reynilda R. De Gracia (born August 20, 1969) and Ma. Rizza R. De Gracia (born January 15, 1972).
- Allegations and Grounds for Nullity
- On December 28, 1998, Rodolfo filed a verified complaint for nullity of marriage before the Regional Trial Court (RTC) of Zamboanga del Norte, alleging that Natividad was psychologically incapacitated to fulfill her essential marital obligations as contemplated by Article 36 of the Family Code.
- The complaint centered on the claim that Natividad’s psychological incapacity was apparent through her emotional immaturity, irresponsibility, and failure to cooperate as a wife and mother, thus rendering her unable to comprehend or perform the duties of marriage.
- Relevant Events and Testimonies
- Prior to the trial, pursuant to an RTC Order dated January 5, 1999, the public prosecutor conducted an investigation to ensure that no collusion existed between the parties.
- During the trial, Rodolfo testified regarding their early acquaintance as students, the hurried marriage following an accidental pregnancy, and subsequent events that demonstrated Natividad’s failure to perform her marital duties.
- Notably, Natividad left the conjugal home, sold their house without his consent, later cohabited with Engineer Terez (with whom she bore a child) and eventually married Antonio Mondarez, thereby reinforcing the allegations of psychological incapacity on her part.
- Psychiatric Evaluation
- Both parties underwent psychiatric examination by Dr. Cheryl T. Zalsos.
- In her two-page report, Dr. Zalsos concluded that both Rodolfo and Natividad exhibited “utter emotional immaturity” and a pattern of behavior deviating from accepted norms.
- With specific emphasis on Natividad, the report noted her lack of willful cooperation as wife and mother, suggesting that her condition, though manifesting after the marriage, had existed from the time of solemnization and was incurable.
- Procedural History and Subsequent Actions
- The RTC rendered a Decision on October 17, 2000, declaring the marriage null on the ground of psychological incapacity, heavily relying on Dr. Zalsos’s findings.
- The Office of the Solicitor General (OSG), representing the Republic of the Philippines, opposed the complaint, arguing that the acts attributed to Natividad only justified legal separation rather than nullity.
- The Court of Appeals (CA) in a Decision dated June 2, 2005, affirmed the RTC’s ruling based on the severity of the alleged personality disorder.
- A subsequent Resolution dated February 3, 2006, denied the Republic’s motion for reconsideration, prompting the present petition for review.
Issues:
- Whether or not the CA erred in sustaining the RTC’s finding of psychological incapacity on the part of Natividad.
- Whether the psychiatric evaluation, and particularly the testimony of Dr. Zalsos, sufficiently established that Natividad’s emotional immaturity, irresponsibility, and alleged promiscuity amounted to a grave, deeply rooted, and incurable psychological disorder as required by Article 36 of the Family Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)