Case Digest (G.R. No. 196359) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Rosanna L. Tan-Andal (petitioner) and Mario Victor M. Andal (respondent) contracted marriage on December 16, 1995 at Saints Peter and Paul Parish, Makati City. Their only child, Ma. Samantha, was born July 27, 1996. The couple resided in a Parañaque City duplex partly owned by Rosanna's family. In 2000, the spouses separated; Rosanna retained custody of their daughter and moved out. After respondent Mario filed for custody on December 18, 2001, Rosanna petitioned on August 6, 2003 for nullity of marriage under Article 36 of the Family Code, alleging respondent’s psychological incapacity to fulfill essential marital obligations. A 2004 prosecutor’s report found no collusion, and the custody and nullity cases were consolidated. At trial, petitioner testified that respondent repeatedly abandoned his wife and child, displayed erratic moods and paranoia, abused substances (admitted marijuana and later found with shabu), dissipated business funds, and ignored marital and parental duti Case Digest (G.R. No. 196359) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Family Background
- On December 16, 1995, Rosanna L. Tan-Andal (Rosanna) and Mario Victor M. Andal (Mario) married in Makati City; their only child, Ma. Samantha, was born July 27, 1996.
- During marital cohabitation, Mario exhibited emotional immaturity, irresponsibility, financial mismanagement, and chronic drug use (marijuana, “shabu”), rendering him incapable of supporting or caring for his wife and child.
- Procedural History
- December 2001: Mario filed for custody of Ma. Samantha.
- August 6, 2003: Rosanna filed for nullity of marriage under Article 36 of the Family Code for Mario’s psychological incapacity. The two cases were consolidated.
- May 9, 2007: RTC, Branch 260, Parañaque City, declared the marriage void ab initio, awarded custody to Rosanna, and declared the donated Parañaque lot and duplex her sole property.
- February 25, 2010: CA reversed, declaring the marriage valid.
- May 11, 2021: This Court granted Rosanna’s Petition for Review under Rule 45.
Issues:
- Psychological Incapacity
- Whether Art. 36 marriages are void ab initio for a spouse’s psychological incapacity, considering:
- The validity of the Molina guidelines (Republic v. Molina) on proof of psychological incapacity.
- The elements of gravity, juridical antecedence, and incurability.
- The role and necessity of expert opinion based on medical/clinical diagnosis.
- The relation between psychological incapacity and grounds for legal separation.
- Whether the interpretation of Art. 36 unduly restricts personal autonomy, liberty, and dignity.
- Property and Custody
- Whether the Parañaque lot and duplex are community property or co-owned under Art. 147 of the Family Code.
- Whether the award of custody of Ma. Samantha to Rosanna comports with Art. 213 of the Family Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)