G.R. No. 188400 - Tani-De La Fuente vs. De La Fuente, Jr.

Maria Teresa B. Tani-De La Fuente and Rodolfo De La Fuente, Jr. first met as students at the University of Santo Tomas and developed a romantic relationship as sweethearts.
After college, Maria Teresa secured employment at the University’s Treasurer’s Office, while Rodolfo, who did not finish college, continued working in his family’s printing press business.

The couple’s courtship evolved, and they eventually married on June 21, 1984, in Mandaluyong City.
Their union produced two children, Maria Katharyn (born May 23, 1985) and Maria Kimberly (born April 6, 1986).

Early in their relationship, Maria Teresa observed that Rodolfo was introverted, prone to jealousy, and lacked ambition.
As their marriage progressed, Rodolfo’s behavior worsened:

He exhibited extreme jealousy, following Maria Teresa and even stalking her by skipping work.
On one occasion, he aggressively brandished a gun at his own 15-year-old cousin due to suspicions regarding Maria Teresa’s fidelity.
His treatment of Maria Teresa extended to sexual abuse, subjecting her to frequent, coerced sexual encounters that involved degrading and physically abusive tactics (e.g., tying her down, using objects to poke her).

Maria Teresa’s attempts to remedy the situation—by consulting a doctor, lawyer, priest, and suggesting marriage counseling—were repeatedly rebuffed by Rodolfo.

On June 3, 1999, Maria Teresa filed a petition for the declaration of nullity of her marriage before the Regional Trial Court of Quezon City.
Initially archived due to Rodolfo’s failure to file a responsive pleading, the case was later revived at Maria Teresa’s request.
The trial court allowed her to present evidence, leading to the involvement of expert witnesses.

Dr. Arnulfo V. Lopez, a clinical psychologist, was engaged as an expert witness and conducted an in-depth interview with Maria Teresa, along with administering a series of psychological tests.
Dr. Lopez’s findings included:

Maria Teresa did not suffer from any severe mental disorder, although she exhibited an emotionally disturbed personality.
Rodolfo was diagnosed with a severe paranoid personality disorder—characterized by extreme jealousy, distrust, and an inability to accept help or treatment—and his behavior was deemed to be gravely incapacitating.
The diagnosis was supported by behavioral observations, corroborated by information from a close acquaintance (Rodolfo’s best friend), and linked to a hereditary factor, as Rodolfo’s father had a psychiatric history.

Based on his analysis, Dr. Lopez recommended the annulment of the marriage on the ground of Rodolfo’s psychological incapacity to perform essential marital obligations.

The trial court, noting Rodolfo’s continuous acts of psychological and physical abuse—culminating in an incident where he poked a gun at Maria Teresa’s head—ruled in favor of nullifying the marriage.
The decision declared that the marriage was null and void owing to respondent’s psychological incapacity, dissolving their conjugal partnership and addressing issues of child custody and support.
Subsequent motions, including a motion for reconsideration by the Office of the Solicitor General (OSG), were denied by the trial court.

The Office of the Solicitor General appealed the trial court’s decision, arguing that:

The trial court erred in relying on Dr. Lopez’s testimony, which it considered hearsay and insufficient due to lack of a thorough personal examination of Rodolfo.
The evidence failed to prove that Rodolfo’s alleged psychological incapacity existed at the time of the marriage.

The Court of Appeals reversed the trial court’s decision, dismissing the petition for nullity of marriage.

Maria Teresa filed a Petition for Review on Certiorari, contending that the trial court had wide discretion in accepting expert evidence and that her evidence sufficed to establish Rodolfo’s psychological incapacity.
The OSG, in its comment on the petition, maintained that while a physician’s opinion was not mandatory, the evidence must still adequately prove psychological incapacity.
Ultimately, the Supreme Court granted the petition, reinstated the trial court’s decision declaring the marriage null and void, and reversed the Court of Appeals’ ruling.

Whether the trial court correctly found that Rodolfo suffered from a psychological incapacity that rendered him unable to comply with or comprehend the essential marital obligations.
Whether the expert testimony of Dr. Lopez was sufficiently reliable and probative, despite his limited opportunity to personally examine the respondent.
Whether the totality of evidence presented established that Rodolfo’s psychological incapacity existed at the time of the marriage celebration.
Whether the reversal by the Court of Appeals—based on claims of hearsay and insufficient data—was justified.