Case Summary (G.R. No. 248675)
Applicable Law
The case is grounded on Article 36 of the Family Code of the Philippines, which addresses psychological incapacity as a basis for declaring a marriage null and void.
Factual Background
Claudine and Jasper began their relationship in 2000, eventually marrying on July 10, 2002, despite initial objections from Claudine’s mother. Claudine became aware of Jasper’s irresponsible and immature behavior early in their marriage, including a failure to secure stable employment and escalating abusive conduct, which culminated in Claudine’s decision to leave. She filed a Petition for Declaration of Nullity of Marriage in 2015, asserting Jasper's psychological incapacity to fulfill his marital obligations.
Initial Ruling by the RTC
On January 30, 2017, the RTC ruled in favor of Claudine, declaring the marriage null and void ab initio based on evidence presented, mainly relying on the expert testimony of Clinical Psychologist Dr. Nedy Tayag, who diagnosed Jasper with Antisocial Personality Disorder. This diagnosis characterized Jasper's behavior as grave, incurable, and detrimental to fulfilling the duties of marriage.
Appeal to the Court of Appeals
The Office of the Solicitor General (OSG) contested the RTC’s decision, and on March 22, 2019, the CA reversed the RTC ruling. The CA held that the evidence did not demonstrate Jasper’s psychological incapacity under Article 36, asserting that his behavior, while irresponsible, did not equate to an inability to comprehend and fulfill marital obligations. Claudine's motion for reconsideration was denied on July 9, 2019.
Issues Presented
The key issues included whether:
- CA erred in disregarding Dr. Tayag's expert testimony.
- Evidence sufficiently demonstrated Jasper’s condition met the criteria of psychological incapacity as defined by Article 36.
- The CA should have dismissed the appeal based on the finality of the RTC decision.
Arguments
Claudine argued the evidence showcased Jasper’s grave psychological incapacity, while the OSG contended the evidence lacked conclusive proof of such incapacity and that the RTC had over-relied on Dr. Tayag's report. Furthermore, the OSG posited that the motion for reconsideration was timely, as it was filed within the appropriate 15-day period based on when the OSG was notified.
Court Ruling
The Supreme Court granted Claudine's petition, finding that the totality of evidence clearly demonstrated Jasper's inability to fulfill ess
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Procedural Background
- This case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- The petition challenges the Decision dated March 22, 2019, and the Resolution dated July 9, 2019, of the Court of Appeals (CA) in CA-G.R. CV No. 109403.
- The CA's Decision reversed the Regional Trial Court's (RTC) ruling dated January 30, 2017, which declared the marriage between Claudine Monette Baldovino-Torres (Claudine) and Jasper A. Torres (Jasper) null and void ab initio due to psychological incapacity.
- The CA's Resolution denied Claudine's Motion for Reconsideration for lack of merit.
Antecedents of the Case
- Claudine and Jasper began their relationship in 2000 after meeting through text messaging and mutual friends.
- They married on July 10, 2002, despite initial objections from Claudine's mother.
- Their early married life was characterized by Jasper's lack of employment and increasing dependence on his parents.
- Claudine pursued her education while Jasper struggled with employment, quitting jobs shortly after being hired.
- Claudine's experience of marital life deteriorated due to Jasper's drinking habits, aggression, and eventual infidelity.
Petition for Declaration of Nullity of Marriage
- Claudine filed a Petition for Declaration of Nullity of Marriage under Article 36 of the Family Code due to Jasper's psychological incapacity.
- The case included testimonies from Claudine, her mother Nora, and Clinical Psychologist Dr. Nedy Tayag, who evaluated both parties.
- Dr. Tayag diagnosed Jasper with Antisocial Personality Disorder, explaining that his psychological incapacity was ingrained and chronic.
Ruling of the RTC
- The RTC ruled on January 30, 2017, declaring the marriage null and void ab initio.
- The c