Case Digest (G.R. No. 219709) Core Legal Reasoning Model
Facts:
The case at hand is between the Republic of the Philippines as the petitioner and Bryan D. Yeban and Maria Fe B. Padua-Yeban as respondents, decided by the Supreme Court on November 17, 2021. Bryan and Fe, both employees of PCI Bank in Cagayan de Oro City, began their romantic relationship in 1996 and subsequently married in a civil ceremony on March 24, 1998, followed by a church wedding on November 7, 1998. They had two sons: Duke Daniel, born on April 6, 1999, and Ethan Duane, born on November 12, 2000.
On October 15, 2009, Bryan filed a petition for the declaration of nullity of their marriage in the Regional Trial Court (RTC) of Cagayan de Oro City, asserting that Fe was psychologically incapacitated to comply with essential marital obligations. Despite being served with summons, Fe did not file an answer, leading to the trial proceeding ex parte. Bryan testified to a longstanding conflict Fe had with her mother and cited several incidents indicative of her behavior that
Case Digest (G.R. No. 219709) Expanded Legal Reasoning Model
Facts:
- Background of the Parties and Their Marriage
- Bryan D. Yeban (petitioner) and Maria Fe B. Padua-Yeban (respondent) first met in 1996 as officemates at PCI Bank in Cagayan de Oro City.
- After a six-month courtship, they became sweethearts and later married in civil rites on March 24, 1998, followed by a church wedding on November 7, 1998, at San Antonio de Padua Parish.
- Their union produced two sons: Duke Daniel P. Yeban (born April 6, 1999) and Ethan Duane P. Yeban (born November 12, 2000).
- Grounds for the Petition for Nullity of Marriage
- On October 15, 2009, Bryan filed a petition with the RTC of Cagayan de Oro City for a declaration of nullity of the marriage on the ground of psychological incapacity under Article 36 of the Family Code.
- Despite the service of summons, Fe did not file an answer, and the matter proceeded directly to trial.
- In his petition, Bryan alleged that Fe had exhibited a longstanding pattern of behavior attributed to a personality disorder:
- Prior indications included Fe confessing issues with her strict and abusive mother.
- The conflict with her mother reportedly led her to seek refuge from familial abuse—a factor that contributed to her later interpersonal difficulties.
- After their marriage, incidents such as a physical altercation with Bryan’s mother (Quirina D. Yeban) and repeated conflicts at her workplace illustrated her uncooperative and uncompromising nature.
- Evidence of Psychological Incapacity
- Bryan presented evidence through witness testimonies and expert reports:
- Testimony of Quirina D. Yeban, who noted Fe’s demeaning behavior and attitude even during their first encounter.
- Dr. Maria Nena R. PeAaranda, a psychiatrist, evaluated Fe and concluded that she suffered from narcissistic personality disorder, which manifested in:
- A lack of empathy toward her family members.
- An inability to attend to the essential marital and parental obligations, including proper care when family members were sick.
- Persistent behavior that caused friction at home and work, further evidencing her incapacity.
- Additional evidence included:
- Documentation of Fe’s unilateral decisions such as her prolonged stay abroad to work in Dubai starting in 2005.
- Testimonies noting that even when returning to the Philippines, Fe maintained separate living arrangements from Bryan, with negligible support for their children despite her earnings.
- Procedural History
- The RTC Decision (January 10, 2013) denied Bryan’s petition for nullity of marriage.
- Bryan filed a Motion for Reconsideration, which was also denied by the RTC on April 29, 2013.
- Bryan then appealed to the Court of Appeals (CA), where on May 7, 2015, the CA reversed the RTC decision and declared the marriage null and void on the ground of Fe’s psychological incapacity as provided by Article 36 of the Family Code.
- The Republic, represented by the Office of the Solicitor General (OSG), moved for reconsideration of the CA decision on July 27, 2015, which was denied, leading to the present petition for review on certiorari before the Supreme Court.
Issues:
- Whether the totality of evidence presented by Bryan sufficiently established that Fe was psychologically incapacitated to comply with the essential marital obligations at the time of the marriage.
- Whether the application of the Molina guidelines—including the requirement that psychological incapacity be medically or clinically identified, alleged, proven by experts, and shown to be permanent—was correctly followed by the lower courts.
- Whether the lack of personal examination and interview of Fe by Dr. PeAaranda invalidates her expert testimony and the evidence of psychological incapacity.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)