G.R. No. 214529 - Tilar vs. Tilar

Petition for Declaration of Nullity
On November 4, 2010, petitioner Jerrysus L. Tilar filed with the Regional Trial Court (RTC) of Baybay City, Branch 14, a petition to declare his marriage to respondent null and void under Article 36 of the Family Code on the ground of psychological incapacity.
The marriage was solemnized on June 29, 1996 by a Catholic priest in Poro, Camotes, Cebu, and one son was born of the union.

Allegations of Psychological Incapacity and Procedural History
Petitioner alleged that respondent developed extreme jealousy, violence, extravagance, gambling habits, and physically harmed him, leading to their separation in 2002; respondent was subsequently living with another man in Cebu City.
A clinical psychologist diagnosed respondent with aggressive personality disorder and histrionic personality disorder, indicating her incapacity to comply with essential marital obligations.
Respondent failed to file an Answer. The Public Prosecutor certified absence of collusion, and trial proceeded with petitioner and his witness testifying.

RTC’s Dismissal and Denial of Reconsideration
On June 3, 2014, the RTC dismissed the petition for lack of jurisdiction over the subject matter, holding that church marriages and their annulment are governed exclusively by Canon Law under the separation of Church and State.
On August 19, 2014, the RTC denied petitioner’s motion for reconsideration, reiterating that validity of church marriages falls outside state jurisdiction.

Petition for Review
Petitioner elevated the case to the Supreme Court via petition for review on certiorari, contending that the Family Code—civil law—governs marriage validity, and civil courts have jurisdiction to grant declaration of nullity.
The Solicitor General manifested that the civil courts indeed have exclusive jurisdiction over contracts of marriage and marital relations under the Family Code and Batas Pambansa Blg. 129.

Whether the RTC had jurisdiction to entertain a petition for declaration of nullity of a marriage solemnized in a church on the ground of psychological incapacity under Article 36 of the Family Code.
Whether the principle of separation of Church and State precludes civil courts from adjudicating the civil effects of a church marriage, including its nullity.