Case Digest (G.R. No. 210518)
Facts:
Republic of the Philippines v. Martin Nikolai Z. Javier and Michelle K. Mercado-Javier, G.R. No. 210518, April 18, 2018, Supreme Court Second Division, Reyes, Jr., J., writing for the Court. The petitioner is the Republic of the Philippines; the respondents are Martin Nikolai Z. Javier (petitioner below in the RTC) and Michelle K. Mercado-Javier (respondent below). Martin and Michelle were married on February 8, 2002. On November 20, 2008, Martin filed a Petition for Declaration of Nullity of Marriage and Joint Custody under Article 36 of the Family Code, alleging that both spouses were psychologically incapacitated to comply with the essential obligations of marriage.At the trial level, Martin testified and offered the psychological findings of Dr. Elias D. Adamos: a Psychological Evaluation Report on Martin and a Psychological Impression Report on Michelle. Dr. Adamos diagnosed both with Narcissistic Personality Disorder, deemed grave and incurable; he personally examined and administered tests to Martin over multiple counseling sessions but did not personally examine Michelle, relying instead on information provided by Martin and a family friend, Jose Vicente Luis Serra (Jose Vicente). The Regional Trial Court (RTC) of Pasig City, Branch 261, dismissed the petition in a Decision dated March 10, 2011 and denied reconsideration on September 7, 2011, finding insufficient basis to conclude psychological incapacity.
Martin appealed to the Court of Appeals (CA). In CA-G.R. CV No. 98015 the CA (opinion by Associate Justice Stephen C. Cruz, with Associate Justices Magdangal M. De Leon and Myra V. Garcia-Fernandez concurring) reversed and set aside the RTC in a Decision dated July 10, 2013, declaring the marriage null and void under Article 36. The Republic moved for reconsiderati...(Pro-only)
Issues:
- Was the Court of Appeals correct in finding that respondent Michelle K. Mercado-Javier was psychologically incapacitated under Article 36 of the Family Code?
- Was the Court of Appeals correct in finding that respondent Martin Nikolai Z. Javier was psychologically incapacitated under Artic...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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