A.M. No. RTJ-04-1861 - Corpus vs. Ochotorena

Edward N. Rivo (petitioner) and Dolores S. Rivo (respondent) met as officemates, began dating in 1978, and were married in a civil ceremony on January 19, 1979, followed by a church wedding on March 14, 1979.
Prior to the marriage, respondent had a child with a former lover—a child whom petitioner accepted and treated as his own—while the couple later had three additional children together.

On April 26, 2005, petitioner filed a Petition for Declaration of Nullity of Marriage under Article 36 of the Family Code.
Petitioner alleged that respondent was psychologically incapable of assuming the essential marital obligations, asserting that this incapacity existed at the time of the marriage even though he only discovered it later.
He pointed to respondent’s alleged neglect—prioritizing work at their family grocery store (even on Sundays) and exhibiting poor personal hygiene—as evidence that she failed in her marital and parental responsibilities.
Petitioner also noted differential treatment toward their children, claiming respondent mistreated one of their sons (Jor-el), which prompted him to assume custody.

Seeking professional help on January 20, 2005, petitioner consulted clinical psychologist Dr. Natividad Dayan, who concluded that petitioner suffered from Narcissistic Personality Disorder.
Dr. Dayan also opined that respondent had a Compulsive Personality Disorder, based on the information provided by petitioner.
In contrast, respondent underwent evaluation by Dr. Nimia Hermilia C. De Guzman, whose findings indicated that she was psychologically capable of fulfilling her marital obligations.

In the October 30, 2009 Decision of the RTC of Las Piñas City (Branch 199), civil case no. 05-0086, the petition was granted.
The RTC declared the marriage null ab initio, basing its decision on its finding that petitioner was psychologically unfit to discharge his responsibilities as a husband—evidenced by his alleged inability to appreciate and support the needs of his wife and family, and his encouragement of antagonism toward respondent by influencing Jor-el.
The RTC emphasized petitioner’s selfishness, narcissistic tendencies, and his infidelities as indicators of his psychological incapacity.

Respondent immediately appealed the RTC decision, and in the September 9, 2013 Decision, the CA reversed and set aside the RTC’s ruling.
The CA observed that the evidence, particularly the reliance on petitioner’s infidelity, did not amount to a clear demonstration of psychological incapacity.
The appellate court clarified that sexual infidelity and abandonment of the conjugal dwelling do not equate to psychological incapacity, but rather constitute grounds for legal separation.
Furthermore, the CA found the evidence insufficient to prove that respondent was psychologically incapable, noting her commitment to fulfilling her marital and financial obligations.

Petitioner filed a Petition for Review on Certiorari challenging the CA decision, arguing that both expert opinions supported his claim of psychological incapacity using the Molina guidelines.
The CA’s January 9, 2014 Resolution denied petitioner’s Motion for Reconsideration, maintaining its earlier reversal of the RTC decision.

Whether the appellate court committed reversible error in reversing the RTC’s decision granting the petition for nullity of marriage.

Specifically, whether the evidence presented was sufficient to establish psychological incapacity as required under Article 36 of the Family Code.
Whether petitioner’s reliance on expert testimonies and the Molina guidelines adequately met the requisite proof standard.

Whether the Petition for Review on Certiorari was procedurally valid, notably regarding the lack of a Verification and a Certificate of Non-Forum Shopping as required by the Rules of Court.