Case Summary (G.R. No. 236827)
Relevant Laws and Jurisprudence
The case is decided under the 1987 Philippine Constitution, specifically Article 36 of the Family Code, which allows for declaration of nullity due to psychological incapacity at the time of marriage. Key jurisprudence includes Tan-Andal v. Andal, which clarified the nature of psychological incapacity and the standards of proof required.
Antecedent Facts
Elizabeth and Jose met in Madrid in 1995 and lived together before marrying in 1998 during Elizabeth’s vacation in the Philippines. Despite the marriage, Jose exhibited irresponsible behaviors including substance abuse, bouts of depression, infidelity (notably with a woman named Joyce David), and neglect of family duties. Elizabeth bore two children with Jose. Over time, marital relations deteriorated due to Jose’s psychological inadequacies and misconduct, culminating in separation in 2008.
Trial Court Findings
The RTC found that Jose suffered from Narcissistic Personality Disorder, which was grave, permanent, and pre-existing at the time of marriage (juridically antecedent). This psychological incapacity manifested as irresponsibility, infidelity, neglect of familial support and care, and even physical abuse of their child. The RTC declared the marriage null and void ab initio based on psychological incapacity, awarded custody to Elizabeth, directed support obligations, and ordered property liquidation.
Psychological Evaluation
Dr. Rowena R. Belen, clinical psychologist, conducted a psychological evaluation based on interviews with Elizabeth and the children, psychological tests administered to Elizabeth, and attempted but failed contact with Jose. Her report diagnosed Jose with Narcissistic Personality Disorder, highlighting traits such as grandiosity, lack of empathy, exploitative behaviors, and persistent inability to fulfill essential marital obligations. This diagnosis aligned with Jose's childhood environment of material indulgence but emotional neglect.
Appeals and Court of Appeals Ruling
The Republic, representing the respondent, challenged these findings before the Court of Appeals, asserting bias and failure to prove the psychological incapacity’s gravity, juridical antecedence, and incurability. The CA reversed the RTC decision, holding that the evidence, including Dr. Belen’s report, lacked factual basis beyond biased information from Elizabeth, and dismissed the nullity petition.
Supreme Court Issues Presented
Elizabeth contested the CA’s ruling, focusing on whether: (i) the psychological evaluation was correctly disregarded, (ii) the CA deviated from established jurisprudence regarding expert and testimonial evidence on psychological incapacity, and (iii) the petitioner sufficiently proved psychological incapacity under prevailing legal standards.
Legal Principles on Psychological Incapacity
Under Article 36 of the Family Code and related jurisprudence, psychological incapacity must be proven by clear and convincing evidence as (1) grave, signifying a serious psychic condition impairing marital duties; (2) incurable in a legal sense, indicating an enduring, persistent incapacity incompatible with the marital relationship; and (3) juridically antecedent, meaning it existed at the time of marriage even if manifest later.
Expert opinion on psychological incapacity is not mandatory but is highly influential. Courts may rely on testimonies of witnesses with knowledge of the spouses’ behavior, and the totality of evidence must demonstrate an unmanageable personality structure incompatible with essential marital obligations.
Court’s Analysis and Findings
The Supreme Court affirmed the RTC’s ruling, emphasizing that:
- Psychological incapacity is a legal concept distinct from medical illness and can be established without direct personal examination of the respondent by experts.
- The absence of personal psychological evaluation of Jose does not invalidate Dr. Belen’s report or other evidence since ample supporting testimony and objective observations were presented.
- Additional psychological evaluation by Dr. Jorge Elias Adamos, conducted subsequent to the CA proceedings, corroborated the diagnosis of Narcissistic Personality Disorder.
- Jose’s psychological incapacity—characterized by irresponsibility, infidelity, neglect, physical abuse, and refusal to fulfill marital and parental obligations—was grave, incurable, and juridically antecedent as it was traceable to his childhood and persisted throughout the marriage.
- The CA erred in disregarding testimonial evidence and expert findings, deviat
Case Syllabus (G.R. No. 236827)
Background and Nature of the Case
- Petition for Review on Certiorari was filed to question the Court of Appeals (CA) Decision dated June 30, 2017 and Resolution dated January 3, 2018 which overturned the January 8, 2016 Decision of the Regional Trial Court (RTC), Quezon City, Branch 94.
- The RTC initially declared the nullity of marriage between Elizabeth A. Alberto and Jose Luis R. Alberto on grounds of psychological incapacity.
- Petition filed by Elizabeth was for a declaration of nullity of marriage due to psychological incapacity of Jose, with the CA dismissing such petition.
Facts and Antecedents of the Marriage
- Elizabeth and Jose met in Madrid, Spain in 1995, started cohabitating in 1996-1997 before Jose returned to the Philippines for work.
- They married on January 14, 1998, in San Fernando, Pampanga; Elizabeth returned to Madrid two days later.
- They had two children, Joaquin Carlos (born 1999) and Ma. Teresa (born 2003).
- From the marriage, numerous personal and marital difficulties arose including Jose’s reported irresponsibility, substance abuse, depression, infidelity, and neglect of family duties.
Allegations of Psychological Incapacity
- Elizabeth testified to Jose's proclivity for alcohol and drug use, depression, repeated infidelities, including sexual relations with a woman named Joyce, and neglect of parental duties including physical abuse of their child.
- Dr. Rowena R. Belen, a clinical psychologist, performed psychological evaluation and concluded Jose suffers from Narcissistic Personality Disorder characterized by:
- Job instability,
- Defiance of social and moral norms,
- Carelessness and neglect of familial rights and support,
- Exploitative interpersonal behavior,
- Grandiosity and entitlement,
- Perpetual need for attention.
- These traits were deemed to be deeply rooted and traceable to a childhood environment marked by material pampering but emotional deprivation.
- Family friend Jenelyn Abeleda corroborated allegations of irresponsibility and infidelity.
RTC Decision and Rationale (January 8, 2016)
- Declared the marriage null and void ab initio due to psychological incapacity of Jose pursuant to Article 36 of the Family Code.
- Awarded custody of minors to Elizabeth with visitation rights to Jose; directed joint support for children.
- Ordered liquidation and partition of community properties.
- Findings emphasized the grave, juridically antecedent, and incurable nature of the psychological incapacity.
- The psychological incapacity manifested as an inability to perform marital obligations including love, respect, fidelity, support, and parental duties.
Republic's Motion for Reconsideration and CA Reversal
- The Republic filed a motion for reconsideration which the RTC denied.
- The CA reversed the RTC, dismissing the petition on the basis that evidence was biased, particularly criticizing the reliance on Elizabeth’s perspective and psychological tests performed only