G.R. No. 209180 - Republic vs. Romero II

Reghis M. Romero II and Olivia Lagman Romero were married on May 11, 1972, at Mary the Queen Parish in San Juan City.
They had two children, Michael (born in 1973) and Nathaniel (born in 1975).
Their relationship began in 1971 in Baguio City when Reghis assisted Olivia’s stranded family along Kennon Road.
A close relationship developed between Reghis and Olivia’s family, with Olivia’s parents playing a significant role in their courtship.

Reghis, then a student focused on finishing his studies and supporting his family, initially attempted to end the relationship due to Olivia’s demanding nature.
Despite Reghis’ desire to break up, Olivia insisted on continuing the relationship, including spending the night at his dormitory.
Under pressure from Olivia’s parents who believed the couple had eloped, Reghis eventually consented to marry after assurances of financial support from her family.

The marriage was characterized by a turbulent and tumultuous relationship, marked by violent fights and frequent jealous fits.
Reghis expressed resentment, stating that he married not out of love but to please Olivia’s parents, which contributed to the ongoing conflict.
After Reghis secured employment as a medical representative and became more engrossed in work, he allegedly devoted minimal time to his marital and familial responsibilities.
By 1986, the marriage had effectively broken down with the couple living separately.

On June 16, 1998, Reghis filed a petition for the declaration of nullity of the marriage before the RTC of Quezon City, Branch 94 (later re-raffled to Branch 225), citing psychological incapacity under Article 36 of the Family Code.
Reghis testified that his marriage was a product of familial pressure rather than genuine love, and he was mentally geared towards personal and familial responsibilities over marital obligations.
Reghis introduced clinical evidence through Dr. Valentina Nicdao-Basilio, a clinical psychologist, who diagnosed him with Obsessive Compulsive Personality Disorder (OCPD).
Dr. Basilio’s evaluation highlighted that his OCPD caused him to obsess over his career to the exclusion of marital duties and family obligations, and she opined that his condition was incurable and present even before the marriage.

Olivia maintained that at all stages—prior to, during, and after the marriage—the couple was capable of fulfilling their essential marital obligations.
She argued that the petition was barred by res judicata because Reghis had previously filed nullity petitions on the ground of her alleged psychological incapacity, which were dismissed.
Due to the absence of her counsel, Olivia was unable to present evidence, a lapse that the RTC interpreted as a waiver of her right to evidence.
The Office of the Solicitor General (OSG), representing the Republic, also opposed the petition.

The Regional Trial Court (RTC) of Quezon City, Branch 225, rendered a Decision on November 5, 2008, declaring the marriage null and void ab initio on the ground of Reghis’ psychological incapacity.

The RTC’s findings relied heavily on Dr. Basilio’s testimony and report, regarding Reghis’ OCPD as gravely interfering with marital duties.
The RTC differentiated the present petition from Reghis’ earlier petitions by emphasizing that the current ground was his own psychological incapacity, not that of Olivia.

Following a motion for reconsideration filed by the Republic and Olivia, the RTC issued a Resolution on July 3, 2009, denying the reconsideration.
The Court of Appeals (CA) affirmed the RTC’s decision in its March 21, 2013 Decision, reiterating that Reghis’ OCPD was permanent, grave, had juridical antecedence, and was incurable.
The CA also denied the motions for reconsideration filed by both the Republic and Olivia in a Resolution dated September 12, 2013.

The Republic filed a petition for review on certiorari (G.R. No. 209180) on November 19, 2013, arguing that Reghis failed to prove the necessary elements of grave, juridically antecedent, and incurable psychological incapacity.
Olivia filed a separate petition (G.R. No. 209253), contending that Reghis’ own admissions and behavior during the marriage proved his capacity to fulfill marital obligations.
On November 13, 2013, the Supreme Court consolidated the petitions and later reviewed the evidence and findings of both lower courts in detail.

Whether the Court of Appeals erred in sustaining the RTC’s declaration of nullity of the marriage on the ground of psychological incapacity.

Whether Reghis adequately demonstrated that his alleged psychological incapacity was grave, had juridical antecedence (i.e., pre-existed before the marriage), and was incurable.
Whether the evidence, particularly Dr. Basilio’s psychological evaluation, sufficiently established an unmistakable incapacity that interfered with the essential marital obligations under Article 36 of the Family Code.
Whether the admissions and conduct of Reghis during the fourteen years of marriage negated the finding of psychological incapacity necessary to nullify the marriage.