Case Digest (G.R. No. 219709)
Facts:
In Republic of the Philippines v. Bryan D. Yeban and Maria Fe B. Padua‑Yeban, G.R. No. 219709, November 17, 2021, the Supreme Court Second Division, Inting, J., writing for the Court, resolved a Rule 45 petition seeking review of a Court of Appeals decision declaring a marriage void for psychological incapacity under Article 36 of the Family Code.Bryan D. Yeban (Bryan) and Maria Fe B. Padua‑Yeban (Fe) married in civil rites on March 24, 1998 and had a church wedding on November 7, 1998; they had two sons, born in 1999 and 2000. In October 2009 Bryan filed in the Regional Trial Court (RTC), Cagayan de Oro City, a Petition for Declaration of Nullity of Marriage under Article 36 of the Family Code, alleging Fe’s psychological incapacity to comply with essential marital obligations. Fe was served but did not file an answer; trial followed with Bryan testifying and presenting witnesses including his mother and Dr. Maria Nena R. Penaranda, a psychiatrist, whose report diagnosed Fe with a personality disorder characterized by lack of empathy and maladaptive behaviors that purportedly caused the marital breakdown.
On January 10, 2013, Branch 19, RTC, Cagayan de Oro City denied Bryan’s petition; its denial of Bryan’s motion for reconsideration was entered on April 29, 2013. Bryan appealed to the Court of Appeals (CA). On May 7, 2015, the CA (Associate Justice Maria Filomena D. Singh, with Justices Badelles and Contreras concurring) reversed the RTC and declared the marriage null and void under Article 36. The Republic, through the Office of the Solicitor General (OSG), moved for reconsideration which the CA denied on July 27, 2015. The OSG then filed the present Petition for Rev...(Pro-only)
Issues:
- Does the lack of a personal examination and interview of the respondent by the psychiatrist (Dr. Penaranda) render her expert findings inadmissible or insufficient to prove psychological incapacity under Article 36?
- Did the totality of the evidence establish that Maria Fe B. Padua‑Yeban was psychologically incapacitated, existing at the time of the marriage, grave, and (as applicable) incurable so as to warrant a decl...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
- (Pro-only)