G.R. No. 237524 - Santos-Macabata vs. Macabata, Jr.

Bebery O. Santos-Macabata, Petitioner and Flaviano Macabata, Jr., Respondent met while working as factory workers in Taiwan in October 1996.
The parties courted, petitioner disclosed a traumatic past relationship, and respondent reassured petitioner that he accepted her despite that past.
Petitioner became pregnant; after their employment contracts ended in Taiwan, the parties returned to the Philippines and married on June 19, 1997 before Judge Ofelia Arellano Marquez of the Metropolitan Trial Court of Quezon City.
The couple lived in Bagong Barrio, Caloocan City, and had two children.

Petitioner became the family breadwinner; the parties argued over respondent's unemployment, drinking, gambling, and womanizing.
During arguments respondent allegedly insulted petitioner by invoking her traumatic past.
The couple moved to petitioner’s parents’ home due to financial difficulty.
In February 2000 respondent secured work as an entertainer in Japan and sent remittances that petitioner deemed insufficient.
Petitioner discovered respondent had indicated "single" in his passport; respondent attributed it to managerial advice.
In June 2002 respondent failed to send money and ceased contact with his family.
After two years of no contact, respondent called his sister and informed petitioner that he would not return because he was living with another woman and told petitioner not to wait for him.
Petitioner’s letters to respondent were answered by respondent’s mistress; petitioner learned from a brother-in-law that respondent had visited the Philippines several times in 2007 while hiding from petitioner.

Aggrieved, petitioner filed a petition dated August 13, 2010 in the Regional Trial Court (RTC), Branch 90, Dasmariñas City, Cavite, seeking declaration of nullity of marriage under the ground of psychological incapacity.
Respondent did not file a responsive pleading; the Office of the Solicitor General (OSG) entered its appearance.
The RTC ordered an investigation for collusion (Order dated July 8, 2011); compliance dated August 22, 2011 confirmed no collusion.
Petitioner submitted, among other evidence, a psychological report by clinical psychologist Dr. H. Nedy L. Tayag based on interviews with petitioner, the couple’s two children, and respondent’s youngest brother, and a residence visit.
Dr. Tayag concluded respondent suffered from antisocial personality disorder and lacked depth in fulfilling marital duties.

In its December 28, 2011 Decision, the RTC granted the petition and declared the marriage null and void ab initio, relying on Dr. Tayag’s report and finding respondent psychologically incapacitated to perform marital obligations prior to marriage.
The OSG filed a motion for reconsideration on January 24, 2012, contending petitioner failed to discharge the burden of proving psychological incapacity.
The RTC denied the motion for reconsideration in ...(Subscriber-Only)

Whether the Court of Appeals erred in reversing the RTC Decision and finding that petitioner failed to prove by clear and convincing evidence that Respondent was psychologically incapacitated to perform his esse...(Subscriber-Only)