Case Summary (G.R. No. 218738)
Procedural History
The Regional Trial Court (Quezon City, Branch 88) granted petitioner’s petition for declaration of nullity, finding both spouses psychologically incapacitated. The Court of Appeals reversed and dismissed the petition. The Supreme Court reviewed the CA decision by petition for review on certiorari under Rule 45 and reversed the CA, declaring the marriage void on the ground of the petitioner’s psychological incapacity.
Core Facts and Contentions
Petitioner alleged that both spouses were psychologically incapacitated to comply with essential marital obligations, asserted lack of mutual love and respect, and recounted separation after being driven from the conjugal home in 1998. Respondent denied those allegations and attributed the separation to petitioner’s persistent womanizing, nocturnal gambling, intoxication, verbal abuse, and threats. Witnesses included an office staff (Gemarie Martin) who corroborated episodes of petitioner being sent away and the receipt of vulgar faxes/letters, and the spouses’ eldest daughter who testified to awareness of petitioner’s girlfriends and cohabitation with another woman.
Expert Evidence — Psychiatric Evaluation
Psychiatrist Dr. Valentina Del Fonso Garcia conducted clinical interviews and a mental status assessment (including interviews of petitioner, the eldest daughter, and interviews of respondent in connection with treatment for the couple’s daughter). In an evaluation dated October 29, 2001, Dr. Garcia diagnosed petitioner with narcissistic and histrionic personality disorders, identified antecedent personality traits traceable to childhood and adolescence (including exposure to an unfaithful father and emotional deprivation), and concluded that petitioner’s pattern of chronic infidelity and related traits manifested a grave psychological incapacity that was persistent and not amenable to effective psychiatric remediation as to the marital relationship.
RTC Finding and Rationale
The trial court accepted the psychiatric evaluation and the testimonial evidence, concluding that both spouses were psychologically incapacitated to perform essential marital obligations (living together, mutual love, respect, fidelity, and mutual help and support). The RTC declared the marriage void under Article 36 of the Family Code.
Court of Appeals Ruling
The Court of Appeals reversed the RTC, agreeing with the Solicitor General’s position that petitioner’s acts of infidelity and irreconcilable differences did not meet the standard for psychological incapacity under Article 36. The CA held that Dr. Garcia’s psychiatric report merely confirmed marital problems and was not conclusive proof of a legally cognizable psychological incapacity; it characterized the evidence as more properly supporting legal separation rather than nullity.
Issues Presented on Review
The Supreme Court addressed whether petitioner established the elements of psychological incapacity under Article 36 — specifically: (1) gravity (serious incapacity to perform essential marital obligations), (2) antecedence (existence of the incapacity at the time of marriage), and (3) incurability or persistence of the incapacity in the legal sense — and whether Dr. Garcia’s psychiatric evaluation and the totality of other evidence sufficed to prove those elements.
Legal Standard — Article 36 and Evolving Jurisprudence
Article 36 requires a showing of psychological incapacity to comply with essential marital obligations. The Court recapitulated the jurisprudential development: earlier characterizations of “mental incapacity” (Santos) and the Molina framework (which emphasized medical proof and incurability) were refined by later decisions (e.g., Marcos and Tan‑Andal). The Court reaffirmed that medical proof or formal clinical testing is not indispensable where the totality of credible evidence demonstrates the legal requisites of antecedence, gravity, and persistence (legal incurability) with respect to a specific marital partner.
Application to the Facts — Antecedence
The Court found that Dr. Garcia’s evaluation and supporting testimony demonstrated that petitioner’s proclivity to pursue multiple concurrent or successive sexual relationships had origins in his formative years (exposure to a philandering father, emotional deprivation) and predated the marriage. The psychiatric account and petitioner’s own admissions established that the patterns were longstanding and not recent developments, satisfying antecedence as required by Article 36.
Application to the Facts — Gravity and Legal Incurability
On gravity, the Court emphasized petitioner’s chronic and admitted infidelity, his lack of genuine remorse or recognition of fidelity as an essential marital obligation, and his testimony that he would “always be cheating.” These facts, together with Dr. Garcia’s diagnosis and the corroborating witness testimony (daughter, office staff, documentary materials such a
...continue readingCase Syllabus (G.R. No. 218738)
Case Caption and Basic Information
- Second Division, G.R. No. 203992, August 22, 2022.
- Parties: Antonio S. Quiogue, Jr. (petitioner) vs. Maria Bel B. Quiogue and the Republic of the Philippines (respondents).
- Decision penned by Justice M. Lopez, with concurrence by Justices Leonen (SAJ, Chairperson), Lazaro-Javier, and Kho, Jr.
- Procedural vehicle: Petition for Review on Certiorari under Rule 45 of the Rules of Court, challenging Court of Appeals Decision dated May 22, 2012 and CA Resolution dated October 3, 2012 in CA-G.R. CV No. 93554 (Rollo pp. 22-32, 34-35).
Relief Sought and Nature of Case
- Petitioner sought declaration of nullity of marriage (Civil Case No. Q-02-46137) on ground of psychological incapacity under Article 36 of the Family Code.
- The petition assails CA rulings that dismissed the petition for declaration of nullity of marriage (Rollo, pp. 22-32; CA Decision fallo at p. 31).
Antecedent Facts — Marriage, Family, and Separation
- Marriage solemnized on October 16, 1980 before the Municipal Mayor of Pasig, Metro Manila (RTC Decision and Judgment).
- Parties have four children: Marie Antonette, Jose Antonio, Anabel, and Maritoni (Petition, Rollo p. 12).
- Parties were separated in fact since 1998 after Maribel allegedly drove petitioner out of the conjugal home; petitioner temporarily stayed in his office at family-owned Nacional Memorial Homes and later at 407-A Valencia Hills Condominium in Quezon City (Petition, Rollo p. 12).
- Petitioner filed petition for separation of property in 2000; petition for declaration of nullity filed in 2001 (Rollo p. 23).
Parties’ Contentions and Positions
- Petitioner’s allegations:
- Both spouses are psychologically incapacitated to comply with essential marital obligations: no mutual love, respect, or emotional/psychological/moral support (Petition, Rollo p. 12).
- Described Maribel as ill-tempered, tactless, irritable, confrontational, and publicly demeaning; alleged persistent marital dysfunction and his own eviction (Trial testimony, Rollo pp. 14, 179).
- Admitted to having "flings" during marriage but characterized his wife's responses as aggravating the situation (Rollo pp. 14, 180-182).
- Respondent Maribel’s denials and allegations:
- Denied driving petitioner out; asserted petitioner voluntarily left to pursue womanizing and habitual gambling; accused petitioner of nocturnal absences, drunkenness, violence, verbal abuse, humiliation, threats, and harassment (Answer, Rollo p. 13).
- Contended that petitioner came home only in the early morning and would leave again; alleged petitioner stayed in his office briefly then returned (Rollo p. 13).
- Disputed Dr. Garcia’s evaluation and contended her disclosures to the psychiatrist were in the context of their daughter’s treatment and not a clinical examination for marital nullity (Rollo pp. 17-18, 246).
Evidentiary Record — Witnesses and Documents
- Witnesses for petitioner:
- Gemarie Martin, office staff at Nacional Memorial Homes, corroborated petitioner’s account: Maribel telephoned the office about petitioner’s whereabouts, confronted staff, petitioner slept in memorial chapel’s empty room after alleged eviction, and Maribel sent petitioner’s clothes via driver; vulgar fax messages sent by Maribel were witnessed (Rollo pp. 14-15).
- Dr. Valentina Del Fonso Garcia (psychiatrist) performed mental status assessment and clinical psychiatric interviews of petitioner and eldest daughter and conducted several interview sessions with Maribel when treating their daughter Anabel; produced Psychiatric Evaluation dated October 29, 2001 recommending consideration of marital nullification on ground of psychological incapacity (Rollo pp. 175-194; Evaluation at p. 194).
- Testimony of petitioner in open court and of eldest daughter Marie Antonette describing petitioner’s affairs and family consequences (Rollo pp. 14, 18, 180-182).
- Documentary evidence:
- Psychiatric Evaluation (Rollo pp. 175-194) and letters written by Maribel to Antonio which were part of Dr. Garcia’s psychiatric assessment (Rollo pp. 175-194; cited by Court).
- Pre-trial and procedural notes:
- Referral to public prosecutor produced report indicating no collusion; cooling-off period granted but reconciliation attempts failed (Rollo, pre-trial notes).
Psychiatric Evaluation and Findings (Dr. Valentina Del Fonso Garcia)
- Dr. Garcia’s Psychiatric Evaluation (October 29, 2001) recommended strong consideration of marital nullification on the ground of psychological incapacity (Rollo p. 194).
- Key diagnostic and factual findings attributed to petitioner Antonio:
- Personality disorders described as "narcissistic and histrionic" and manifestations of chronic philandering, rooted in childhood and adolescent experiences (Rollo pp. 192-193).
- Noted sense of entitlement, exploitative behavior, lack of empathy toward wife and children, marked attention-seeking demeanor, dependent traits, and propensity to seek thrill and pleasure in relationships (Rollo p. 193).
- Pathological identification with his philandering father and emotional deprivation in childhood leading to maladaptive adult romantic behavior (Rollo pp. 180, 192-193).
- Antonio’s extra-marital affairs were characterized as ego-gratifying, lacking warmth and depth, and persistent from before and throughout the marriage (Rollo pp. 180-182, 192).
- Dr. Garcia’s view on incurability and antecedence:
- Opined that the personality disorder pre-dated the marriage and could no longer be effectively addressed through psychiatric treatment (Rollo p. 193).
- Found incapacity to be enduring with respect to the marital relationship and specifically directed at petitioner’s wife (Rollo pp. 192-194).
Trial Court (RTC, Branch 88, Quezon City) Ruling
- RTC Decision dated May 8, 2008 granted the petition and declared the marriage void under Article 36 of the Family Code, finding both parties psychologically incapacitated to perform essential marital obligations (Rollo pp. 12-20; RTC J