Case Summary (G.R. No. 248569)
Background and Marriage Details
The case revolves around the marriage of Ericson and Romelia, which took place in Lasam, Cagayan, on January 2, 2003. The couple welcomed their daughter, Keirah Angela Cabutaje, shortly after, on February 24, 2003. Their initial living situation included residing with Ericson’s parents. Over time, Romelia sought work abroad, initially sending financial support to Ericson but later failing to fulfill her parental obligations, demonstrating signs of psychological instability and marital incapacity.
Petition for Nullity
On August 10, 2012, Ericson filed a petition before the Regional Trial Court (RTC) for the declaration of nullity of his marriage to Romelia, arguing both parties were psychologically incapacitated under Article 36 of the Family Code. The RTC subsequently ruled in Ericson's favor, declaring the marriage void ab initio based on established personality disorders that hampered their ability to fulfill essential marital duties.
Court of Appeals Reversal
The Office of the Solicitor General sought to contest the RTC's ruling, ultimately prompting an appeal to the Court of Appeals (CA). The CA reversed the RTC’s decision, citing insufficient evidence of psychological incapacity, particularly criticizing the credibility of Dr. Nedy Tayag’s psychological assessment, which was not based on a personal examination of Romelia but rather on second-hand information from Ericson and his witnesses.
Petitioner's Claims
Ericson contested the CA's reversal, asserting that the RTC's findings were adequately supported and that the absence of a personal examination of Romelia by Dr. Tayag should not invalidate her report. He referenced established legal precedents indicating that expert assessments could rely on the experiences and testimonies of the spouse seeking nullity. Ericson maintained that Romelia's abandonment of her family and subsequent behaviors illustrated a clear psychological incapacity.
Office of the Solicitor General's Argument
The OSG countered Ericson's assertions by stating that psychological incapacity was not proven, also arguing that emotional immaturity or infidelity alone does not suffice to void a marriage. The OSG's highlights included questioning the reliability of evidence lacking a personal evaluation of Romelia.
Supreme Court's Resolution
Upon reviewing the records, the Supreme Court granted Ericson's petition, reinstating the RTC’s original ruling. The Court emphasized its deference to the RTC's findings, particularly noting the personal observations of the witnesses and the dynamics of the marriage. It upheld the importance of Article 36, which allows for the declaration of nullity when psychological incapacity affects one or both parties, arguing that expert opinions do not require perfect circumstances but should stem from a comprehensive evaluation of marital behaviors.
Expert Testimony and Evidence Assessment
The Court underscored that while Dr. Tayag's report was derived from testimonies and not a direct examination, it was still substantive enough to establish Romelia's psychological incapacity. The Court observed that behaviors exhibited by Romelia, including her failure to provide care for her daughter and engaging in e
...continue readingCase Syllabus (G.R. No. 248569)
Background and Procedural History
- Ericson C. Cabutaje filed a Petition for Review on Certiorari assailing the Court of Appeals' Decision and Resolution that reversed the Regional Trial Court’s declaration nullifying his marriage to Romelia A. Cabutaje on grounds of psychological incapacity.
- The marriage was solemnized on January 2, 2003; they had one daughter, Keirah Angela Cabutaje.
- Marital difficulties began during their work abroad, characterized by lack of communication, Romelia’s inconsistent financial support, and her eventual abandonment of familial duties.
- Ericson filed a petition for the declaration of nullity of marriage under Article 36 of the Family Code citing psychological incapacity of both parties.
- The RTC granted the petition; the OSG moved for reconsideration, which was denied.
- The CA reversed the RTC decision citing insufficient evidence, particularly due to lack of personal examination of Romelia by the expert psychologist and failure to identify the root cause of the alleged incapacity.
- Ericson appealed to the Supreme Court, contesting the CA's ruling.
Issues Presented
- Whether the evidence sufficiently establishes the psychological incapacity of either or both spouses to fulfill essential marital obligations under Article 36 of the Family Code, thereby declaring the marriage void ab initio.
Facts Material to the Case
- Romelia worked abroad leaving Ericson in charge of their child; financial support waned over time.
- Romelia left for Hong Kong, leaving the child with her sister and having an extramarital affair.
- Psychological evaluation by Dr. Nedy Tayag, clinical psychologist, based on interviews with Ericson, his sister, and a mutual friend, identified narcissistic personality disorder in Ericson and histrionic personality disorder with antisocial features in Romelia.
- Romelia allegedly demonstrated grave disregard of marital and parental duties, including financial neglect, custody abandonment, and infidelity.
Legal Framework
- Article 36 of the Fam