G.R. No. 86561 - Bernardo vs. Balagot

Martin Nikolai Z. Javier (Martin) and Michelle K. Mercado-Javier (Michelle) were married on February 8, 2002.
On November 20, 2008, Martin filed a Petition for Declaration of Nullity of Marriage and Joint Custody of their minor child Amanda M. Javier, invoking Article 36 of the Family Code.
Martin alleged that both he and Michelle were psychologically incapacitated to comply with the essential obligations of marriage.

Martin testified on his behalf and presented psychological findings of Dr. Elias D. Adamos, consisting of a Psychological Evaluation Report on Martin and a Psychological Impression Report on Michelle.
Dr. Adamos diagnosed both Martin and Michelle with Narcissistic Personality Disorder, regarding their condition as grave and incurable, rendering them incapacitated to perform marital obligations.
Dr. Adamos did not personally examine Michelle due to her non-cooperation, relying instead on information from Martin and their mutual friend Jose Vicente Luis Serra (Jose Vicente).
Martin testified about Michelle’s confrontational behavior, tendency to challenge him, recklessness, and extra-marital affairs as narrated in the psychological evaluation.

The Regional Trial Court (RTC) of Pasig City dismissed the petition on March 10, 2011, finding no sufficient basis to declare the marriage null due to psychological incapacity.
The RTC found Martin's testimony self-serving and not supportive of Dr. Adamos' diagnosis; the court viewed Martin as patient and responsible in his role as husband and father despite alleged wrongdoings by Michelle.
The motion for reconsideration filed by Martin was denied by the RTC on September 7, 2011.

Martin appealed to the Court of Appeals (CA), arguing that the psychologist’s personal examination of Michelle was unnecessary and that sufficient evidence supported his own psychological incapacity.
The Republic of the Philippines opposed the appeal, asserting the evidence was insufficient and largely hearsay or self-serving.
The CA reversed the RTC on July 10, 2013, declaring the marriage null and void ab initio due to psychological incapacity of both spouses, based on Martin’s and Jose Vicente’s testimonies.
The CA denied the Republic’s motion for reconsideration on November 28, 2013.

The Republic filed a petition for review, arguing there was no basis to accept the CA’s finding especially regarding Michelle’s psychological incapacity since there was no direct or independent witness testimony substantiating such claim, and Martin’s testimony was self-serving.

Whether or not the respondents’ marriage should be declared null and void due to psychological incapacity under Article 36 of the Family Code.
Whether the psychological incapacity of Michelle was sufficiently proven despite the absence of her personal psychological evaluation.
Whether Martin’s psychological incapacity was sufficiently established to warrant nullity of marriage.