Case Digest (G.R. No. 164493)
Facts:
Jocelyn M. Suazo filed on October 8, 1997 a petition with the RTC, Branch 119, Pasay City for declaration of nullity of her marriage to Angelito Suazo contracted on March 3, 1986, alleging Article 36 of the Family Code psychological incapacity; the parties separated in July 1987 and Angelito did not answer or submit to examination. The RTC declared the marriage void for psychological incapacity on January 29, 1999, the Court of Appeals reversed on July 14, 2004, and the Supreme Court rendered judgment on March 10, 2010.
Issues:
- Did petitioner prove that Angelito Suazo was psychologically incapacitated to comply with the essential marital obligations at the time of the celebration of the marriage under Article 36?
- Did the Court of Appeals commit reversible error in setting aside the RTC judgment?
Ruling:
The petition was denied and the Court affirmed the Court of Appeals' decision. The Court held that petitioner failed to prove psychological incapacity under Article 36, and that the Court of Appeals committed no reversible error in reversing the RTC; costs were imposed against the petitioner.
Ratio:
The Court applied the established standards in Santos v. Court of Appeals and Republic v. Court of Appeals (Molina), reaffirmed and tempered by later cases such as Marcos v. Marcos, Te v. Yu-Te, and Pesca v. Pesca, requiring proof of the root cause medically or clinically identified and the three hallmarks of gravity, juridical antecedence, and incurability. The psychologist's opinion was unreliable because it rested principally on information supplied by petitioner without a thorough, in-depth assessment of respondent; although personal examination is not mandatory, expert conclusions must be based on adequate and objective evaluation, and petitioner’s own testimony failed to show that the incapacity existed at the time of the marriage.
Doctrine:
- Article 36 of the Family Code requires proof of psychological incapacity characterized by gravity, juridical antecedence, and incurability.
- The burden of proof to nullify a marriage under Article 36 rests on the petitioner, and doubts are resolved in favor of the marriage.
- The root cause of the incapacity must be medically or clinically identified and linked to the manifestations alleged.
- A personal examination of the respondent by an expert is desirable but not mandatory; the *totality of evidence* may suffice.
- Expert opinion must be founded on a thorough, in-depth assessment and reliable sources to be conclusive.
- Trial court factual findings are accorded respect but appellate courts may reverse when such findings are clearly and manifestly erroneous.