Case Digest (G.R. No. L-45031)
Facts:
This case involves the Republic of the Philippines as the petitioner and Cesar Encelan as the respondent under G.R. No. 170022. The dispute centers around the nullity of the marriage between Cesar and his wife Lolita Castillo-Encelan. Cesar and Lolita married on August 25, 1979, and had two children, Maricar and Manny. In pursuit of better employment opportunities, Cesar began working in Saudi Arabia on May 15, 1984. While still in Saudi Arabia, Cesar learned on June 12, 1986, that Lolita had been engaged in an extramarital affair with Alvin Perez. Their relationship deteriorated when Lolita allegedly left their home in 1991 to cohabit with Alvin.
On June 16, 1995, Cesar filed a petition with the Regional Trial Court (RTC) of Manila, Branch 47, to declare his marriage to Lolita void due to her supposed psychological incapacity. In response, Lolita denied the allegations of infidelity, claiming that her relationship with Alvin was purely professional and contended that irreconc
Case Digest (G.R. No. L-45031)
Facts:
- Marriage and Family Background
- On August 25, 1979, Cesar married Lolita, and their union produced two children, Maricar and Manny.
- The marital relationship began traditionally but eventually faced serious challenges leading to discord.
- Employment, Alleged Infidelity, and Separation
- Cesar left for Saudi Arabia on May 15, 1984, to support his family financially.
- On June 12, 1986, while still abroad, Cesar learned that Lolita was involved in an illicit affair with Alvin Perez.
- In or around 1991, Lolita allegedly abandoned the conjugal home with their children and began living with Alvin, resulting in the separation of the spouses.
- Filing of the Petition for Nullity and Evidence Presented
- On June 16, 1995, Cesar filed a petition for the declaration of nullity of the marriage, invoking Lolita’s alleged psychological incapacity.
- At the trial, Cesar contended that Lolita’s infidelity and her abandonment of the family home were indicative of her inability to meet essential marital obligations.
- Cesar submitted a psychological evaluation report prepared by Dr. Fareda Fatima Flores of the National Center for Mental Health.
- The report indicated that Lolita did not suffer from any major psychiatric illness.
- Observations in the report noted interpersonal issues, a pattern of changing jobs, and reluctance to accompany Cesar abroad, yet these factors were deemed insufficient to substantiate a claim of psychological incapacity.
- Rulings of the Lower Courts
- The Regional Trial Court (RTC) of Manila, Branch 47 (June 5, 2002) declared the marriage null, finding that Lolita was psychologically incapacitated to conform to essential marital obligations.
- The Court of Appeals (CA) initially set aside the RTC’s decision, ruling that Lolita’s acts of infidelity and abandonment did not amount to serious cases of personality disorder or psychological illness.
- The CA stressed that infidelity is generally a ground for legal separation rather than annulment on the basis of psychological incapacity.
- Upon petition for reconsideration, the CA reversed its earlier decision and affirmed the RTC’s ruling by finding two indicative circumstances of psychological incapacity in Lolita:
- Her unwarranted refusal to fulfill marital obligations.
- Her willful and deliberate act of abandoning the conjugal dwelling.
- The Present Petition and Arguments by the Parties
- The Office of the Solicitor General (OSG) filed the petition for review on certiorari challenging the CA’s amended decision.
- The OSG argued that:
- Dr. Floresa’s psychological evaluation report failed to establish any psychological illness or prove the juridical antecedence, gravity, and incurability of Lolita’s alleged condition.
- Acts of infidelity and abandonment, even if true, do not inherently constitute psychological incapacity but are merely grounds for legal separation.
- In response, Cesar maintained that Lolita’s conduct demonstrated grave and incurable psychological incapacity, warranting the nullity of their marriage.
Issues:
- Whether sufficient legal basis exists to annul Cesar’s marriage to Lolita on the ground of psychological incapacity.
- Whether the evidence presented, particularly the psychological evaluation report, sufficiently establishes the juridical antecedence, gravity, and incurability required to prove psychological incapacity under Article 36 of the Family Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)