G.R. No. 224638 - Cortez vs. Cortez

Case Summary (G.R. No. 224638)

Factual Background

The parties married on March 5, 1990. Petitioner alleged that he was induced to marry after an episode at a social gathering in which he lost consciousness and later awoke in respondent’s bedroom; that respondent and her relatives compelled him to marry to lift a POEA hold-departure order so he could work abroad; that he never cohabited or had sexual relations with respondent and that respondent already had a prior husband and child; that he provided intermittent financial support but later ceased support after learning of respondent’s alleged prior relationship; and that a semenal examination performed after their marriage allegedly showed low sperm count. Respondent countered that the relationship began as a genuine courtship in 1988, that petitioner was a responsible husband who designated her as his allottee, that petitioner attended the baptisms of their two children, that marital problems arose after petitioner became involved with another woman, and that she sought support for the children and consulted a psychiatrist who opined on both parties’ personalities.

Trial Court Proceedings

Petitioner filed an amended petition for declaration of nullity of the marriage on grounds of psychological incapacity. The RTC conducted trial and received documentary evidence, photographs, letters, a compromise agreement, and the psychiatric evaluation of Dr. Felicitas Artiaga-Soriano. On July 9, 2012, the RTC denied the petition, finding the marriage valid and sustained by evidence of preexisting courtship, petitioner’s voluntary acts before and after the marriage, cohabitation, attendance at baptisms, designation of respondent as allottee, financial support, and documentary proofs identifying the children as “my children” and “our children.” The RTC also found Dr. Soriano’s conclusions insufficient to establish psychological incapacity.

The Parties’ Contentions

Petitioner maintained that he lacked the intention and capacity to perform essential marital obligations because he was forced into marriage and later demonstrated dependency and passive-aggressive traits shown in Dr. Soriano’s psychiatric report, which, he argued, established antecedence, gravity, and incurability of psychological incapacity. Respondent contended that the relationship was initially loving, that she fulfilled marital and parental duties, that petitioner voluntarily designated her as allottee and supported the children, and that petitioner’s allegations and psychiatric evidence were self-serving, uncorroborated, and contradicted by letters and documentary evidence showing her care and love for the family.

Court of Appeals Decision

The Court of Appeals affirmed the RTC by Decision dated November 5, 2015 and denied reconsideration on May 13, 2016. The CA credited respondent’s account of an initially loving relationship, emphasized petitioner’s documentary acts before and after marriage, and found photographs, letters, allotment designations, and educational plans to evince petitioner’s genuine care for respondent and the children. The CA held that the totality of evidence failed to establish psychological incapacity as defined in law and jurisprudence, and that Dr. Soriano’s report did not demonstrate the requisite antecedence, gravity, and incurability.

Issue Presented to the Supreme Court

The sole issue presented was whether the Court of Appeals erred in sustaining the RTC’s finding that petitioner failed to prove that either party was psychologically incapacitated under Article 36 of the Family Code, thereby rendering the marriage void.

Supreme Court Ruling and Disposition

The Supreme Court denied the petition for review on certiorari and affirmed the Decision dated November 5, 2015 and the Resolution dated May 13, 2016 of the Court of Appeals. The Court upheld the factual findings of the CA and RTC as supported by the record and reiterated that petitioner failed to establish psychological incapacity in accordance with the legal standards.

Legal Basis and Reasoning

The Court reiterated the elements of psychological incapacity under Article 36: an inability truly to commit to the essentials of marriage, reference to the essential obligations of marriage (conjugal act, community of life and love, mutual help, procreation and education of offspring), and that the inability must constitute a psychological abnormality. The Court applied the tripartite test from Yambao v. Republic of the Phils. and the formulation of (a) gravity, (b) juridical antecedence, and (c) incurability as stated in Republic of the Philippines v. Katrina S. Tobora-Tionglico.

Application of Precedent and Evaluation of Evidence

The Court declined to disturb concurrent factual findings of the RTC and CA, invoking the settled doctrine that this Court, in a Rule 45 petition, does not reweigh evidence and that factual findings of the CA carry particular weight when they coincide with those of the trial court, citing Villanueva v. CA and Valdez v. Reyes. The Court found the documentary and testimonial record—postcard dated August 28, 1988, petitioner’s signature on the marriage license application, allotment slips naming respondent as allottee, photographs depicting intimacy, letters, attendance at baptisms, educational plans, and a com

Case Syllabus (G.R. No. 224638)

Parties and Procedural Posture

Rolando D. Cortez filed a petition for review on certiorari under Rule 45 contesting the Court of Appeals' affirmation of the Regional Trial Court's denial of his petition for annulment of marriage.
Luz G. Cortez was the respondent in the annulment proceedings and opposed the petition before the trial court and the Court of Appeals.
The trial court denied the petition for declaration of nullity dated July 9, 2012, and denied petitioner’s motion for reconsideration on October 4, 2012.
The Court of Appeals rendered a decision dated November 5, 2015 affirming the RTC, and denied petitioner’s motion for reconsideration by Resolution dated May 13, 2016.
The Supreme Court rendered the challenged decision authored by Justice Peralta on April 10, 2019 and denied the petition for review on certiorari.

Key Facts

The parties were married on March 5, 1990 following a relationship that petitioner alleged began by coercion and respondent alleged began as a loving courtship.
Petitioner alleged that he was intoxicated, found in respondent's room, and was compelled by respondent’s relatives to marry to lift a POEA hold-departure order.
Petitioner alleged noncohabitation, absence of consummation, and later discoveries that respondent had a prior husband and child in Samar.
Petitioner acknowledged participating in children’s baptisms, designating respondent as his allottee, and providing financial support at times.
Petitioner later learned of respondent’s prior child and alleged a subsequent low sperm count test to dispute paternity.

Claims and Pleadings

Petitioner asserted that he and respondent were psychologically incapacitated to comply with the essential marital obligations at the time of the marriage under Article 36 of the Family Code.
Respondent denied petitioner’s allegations of coercion and noncohabitation and asserted an initially loving and caring marital relationship that later deteriorated due to petitioner’s infidelity.
Respondent filed an abandonment complaint that was later dismissed following a compromise agreement obligating petitioner to support the children.

Evidence Presented

Petitioner relied on the psychiatric evaluation report of Dr. Felicitas Artiaga‑Soriano diagnosing petitioner with dependency inclination and passive‑aggressive personality traits and diagnosing respondent with an anti‑social personality disorder.
Petitioner offered testimony and documentary exhibits including a postcard dated August 28, 1988, marriage license application dated February 22, 1990, allotment slips, photographs showing intimacy, letters, baptismal records, and an authorization to Scholarship Plan Phils., Inc. describi