Case Summary (G.R. No. 148233)
Key Dates and Procedural History
Marriage: July 24, 1993. Separation: 1997. Petition for declaration of absolute nullity filed: March 2, 2002 (Civil Case No. 02-6428, RTC Antipolo). RTC decision declaring marriage void ab initio: October 25, 2004 (amended July 19, 2005 to correct respondent’s name). Court of Appeals reversal and affirmation of validity of marriage: August 31, 2007; CA resolution: November 20, 2007. Supreme Court decision reinstating the RTC: May 26, 2009.
Applicable Law and Constitutional Policy
Governing constitutional framework: 1987 Philippine Constitution (policy to protect and strengthen the family and to regard marriage as inviolable). Governing statutory provision: Article 36, Family Code (psychological incapacity as ground for declaration of nullity). Relevant marital obligation provisions: Articles 68–71 and Articles 220, 221, 225 (as referenced by the courts) concerning duties to live together, mutual love, respect, fidelity, support and household management.
Factual Background Presented at Trial
Petitioner alleged that respondent was emotionally immature, irresponsible, dependent on his mother for financial support and decisions, failed to secure or maintain employment, and that their sexual relations were minimal and unsatisfactory (about once per month). Petitioner testified that respondent often relied on his mother for lodging and financial support, lied about having employment, refused to move away from his parents’ home, became physically violent when drunk, and resisted having children. Petitioner and a relative of respondent (Florida de Ramos) testified to corroborate these facts.
Expert Evidence
Psychiatrist Dr. Cecilia Villegas examined petitioner and based on interviews and the factual history she diagnosed respondent as suffering from Dependent Personality Disorder associated with severe inadequacy related to masculine strivings. Dr. Villegas explained the psychodynamics: prolonged and dominant maternal dependence, role reversal in family, ambivalence in identity, unconscious guilt inhibiting sexual relations, and a personality structure rooted in early development. She characterized the condition as grave, deeply ingrained, permanent and incurable for purposes of Article 36, and causally linked to respondent’s failure to assume essential marital obligations.
RTC Findings and Disposition
The RTC credited petitioner’s evidence and the expert’s opinion, found respondent psychologically incapacitated to assume the essential obligations of marriage, and declared the marriage null and void ab initio pursuant to Article 36. The court ordered appropriate entries in civil records and forwarded copies of its decision to the Public Prosecutor and the Solicitor General.
Grounds of Appeal to the Court of Appeals
The Solicitor General appealed, arguing chiefly that (a) Dr. Villegas did not personally examine respondent and therefore her report was inadequate; and (b) petitioner failed to prove that the alleged psychological defects existed at the inception of the marriage or that they were grave and incurable. The CA reversed the RTC, holding that the evidence did not demonstrate psychological incapacity as required by Article 36 and controlling jurisprudence; it characterized respondent’s conduct as immaturity and irresponsibility rather than psychological incapacity and found no adequate proof of psychiatric antecedence at the time of marriage.
Legal Standards Governing Article 36 (Jurisprudential Guidelines)
The Supreme Court reiterated controlling standards (as articulated in Republic v. Court of Appeals and Molina and related cases): plaintiff bears the burden of proof and doubts favor the continuity of marriage; the root cause of incapacity must be medically/clinically identified, pleaded, proven by experts and explained in the decision; the disorder must have existed at the time of marriage; it must be grave and permanent or incurable (or relatively incurable as to the spouse); it must be a psychological, not merely physical, incapacity; the incapacity must be relevant to marital obligations; and trial court findings on credibility and expert evidence merit deference by appellate courts. The Santos criteria (gravity, juridical antecedence, incurability) and the Court’s emphasis in Te v. Te on expert opinion as decisive were also applied.
Supreme Court’s Assessment of the Evidence
The Supreme Court found that petitioner satisfied her evidentiary burden under Article 36: (1) Totality of evidence — petitioner’s sworn testimony (subject to cross-examination) and corroboration by a close relative provided the factual foundation upon which the expert opinion reasonably relied; (2) Expert proof and explanation — Dr. Villegas, who testified in court, linked respondent’s manifestations to Dependent Personality Disorder, explained the psychodynamics and causal relationship to marital failures, and described the condition as severe and deeply ingrained; (3) Antecedence — the Court accepted the expert’s and witnesses’ testimony that the disorder had its roots prior to marriage though became manifest under marital stress; (4) Gravity and incurability — the Court found the disorder grave enough to incapacitate respondent from the essential duties of husband and father and accepted the expert’s opinion of permanence given its early developmental origin; (5) Relevance to marital obligations — respondent’s inability to make decisions, provide support, cooperate in household and sexual relations, and to separate decisively from parental domination demonstrated failure to assume essential marital obligations under Articles 68–71.
Rebuttal to Appellate Court Reasoning
The Supreme Court rejected the CA’s characterizations and speculative inferences (e.g., that requests for maternal assistance reflected mere embarrassment over unemployment or that refusal to have children reflected responsible judgment). It emphasized appellate restraint: appellate courts should not substitute their own credibility assessments for those of the trial court, especially where the trial court accepted witness credibility and an exp
Case Syllabus (G.R. No. 148233)
Procedural History
- Petition for review on certiorari under Rule 45 of the Rules of Court filed in the Supreme Court, assailing the Decision of the Court of Appeals in CA-G.R. CV No. 86162 dated August 31, 2007 and its Resolution dated November 20, 2007.
- Petitioner Marietta C. Azcueta filed a petition for declaration of absolute nullity of marriage under Article 36 of the Family Code on March 2, 2002 in the Regional Trial Court (RTC) of Antipolo City, Branch 72, docketed as Civil Case No. 02-6428.
- Respondent Rodolfo Azcueta failed to appear and answer despite service of summons; RTC directed the City Prosecutor to investigate alleged collusion; City Prosecutor Wilfredo G. Oca reported no collusion on August 16, 2002.
- On August 21, 2002, the Office of the Solicitor General entered appearance for the Republic and authorized the City Prosecutor to appear on the State’s behalf under supervision and control of the Solicitor General.
- RTC rendered decision dated October 25, 2004 declaring the marriage null and void ab initio under Article 36; Amended Decision issued July 19, 2005 to correct the respondent’s first name in the caption.
- The Solicitor General appealed; the Court of Appeals reversed the RTC in CA-G.R. CV No. 86162 (Aug. 31, 2007), holding the marriage valid; petition for certiorari followed to the Supreme Court.
- Supreme Court granted the petition, reinstated the RTC Amended Decision of July 19, 2005, and ordered appropriate entries in civil registries; concurrence noted by Puno, C.J. (Chairperson), Corona, Leonardo-De Castro, and Bersamin, JJ.
Facts
- Parties met in 1993 and married less than two months after meeting on July 24, 1993 at St. Anthony of Padua Church, Antipolo City; petitioner was 23 years old and respondent 28 at time of marriage.
- The spouses separated in 1997 after four years of marriage; they had no children.
- Petitioner’s core allegations: respondent was psychologically incapacitated to comply with essential marital obligations—emotionally immature, irresponsible, heavily dependent on his mother, failed to adapt to married life, failed to obtain or maintain employment, and relied on his mother for financial support including payment of rent.
- Specific incidents as recounted by petitioner: respondent pretended to have a job and presented money from his mother as salary; respondent refused petitioner’s request to move away from his parents; respondent allegedly became physically violent when intoxicated; sexual relations were infrequent (about once a month) and unsatisfactory; respondent stated sex should not be “enjoyed nor abused” and expressed unwillingness to have a child because he claimed unpreparedness.
- Petitioner attempted to motivate respondent to find work by buying a newspaper, clothes, shoes, and giving money, but respondent attributed his inaction to age limits or lack of suitable clothes and later admitted fabricating employment to stop petitioner’s nagging.
- Witness Florida de Ramos (respondent’s first cousin and at one time living with respondent’s family) corroborated petitioner’s account of respondent’s non-employment, dependence on his mother, the mother’s payment of rent, and respondent’s continuing residence at his mother’s house rather than living together with petitioner.
- Psychiatrist Dr. Cecilia Villegas examined petitioner for psychological evaluation, reviewed the history and facts presented by petitioner, and testified that respondent displayed a Dependent Personality Disorder associated with severe inadequacy related to masculine strivings; she explained the psychodynamics, etiologic root, manifestations, permanence, and effects on marital functions.
Trial Court Findings and Judgment
- RTC, upon the “preponderant evidence presented by the petitioner,” found respondent totally failed in his commitments and obligations as a husband, describing his emotional immaturity and irresponsibility as grave with no showing of improvement.
- RTC found respondent failed to have satisfactory sexual relations due to unconscious guilt and inability to distinguish between mother and wife; diagnosed respondent as suffering from Dependent Personality Disorder rendering him unable to make decisions or carry out responsibilities as a husband.
- RTC concluded that marital obligations to live together, observe mutual love, respect, and support were not fulfilled by respondent, and declared the marriage null and void ab initio pursuant to Article 36 of the Family Code (Decision dated October 25, 2004).
- RTC ordered the National Statistics Office and Local Civil Registrar of Antipolo City to make proper entries and directed copies of decision to the Public Prosecutor and Solicitor General; an Amended Decision was issued July 19, 2005 to correct a typographical error in the caption.
Appellate Contentions and Court of Appeals Rationale
- The Solicitor General argued on appeal that Dr. Villegas’ psychiatric report was founded solely on petitioner’s version and lacked personal examination of respondent, and that there was no showing the alleged psychological defects existed at inception of marriage or that they were grave, permanent, and incurable.
- The Court of Appeals reversed the RTC, holding petitioner failed to sufficiently prove psychological incapacity or its existence prior to marriage and that such incapacity was grave and incurable.
- CA’s factual reasoning included: parties lived harmoniously and independently during the first years of marriage; respondent’s requests for financial assistance could be due to embarrassment for not contributing; respondent’s reluctance to have a child could reflect responsible judgment given unemployment; respondent’s alleged irresponsibility and closeness to mother could be youthful immaturity rather than psychological-rooted incapacity.
- CA relied on jurisprudence (Deldel v. Court of Appeals, Pesca v. Pesca, Navarro, Jr. v. Cecilio-Navarro) to hold that immaturity or irresponsibility alone do not equate to psychological incapacity and concluded the marriage remained valid.
Issue Presented to the Supreme Court
- Whether the totality of the evidence presented by petitioner established that respondent was psychologically incapacitated to comply with the essential