Case Summary (G.R. No. 209278)
Key Dates and Procedural Posture
Alfredo filed a complaint for declaration of nullity of marriage on January 3, 2005 before the Regional Trial Court (RTC) of Olongapo City. The RTC rendered judgment declaring the marriage void for respondent’s psychological incapacity on September 25, 2007. The Court of Appeals affirmed on September 28, 2012 and denied reconsideration on September 18, 2013. Irene filed a petition for review on certiorari with the Supreme Court, which denied the petition and affirmed the CA judgments (G.R. No. 209278; decision rendered in 2021).
Applicable Law and Constitutional Basis
Article 36 of the Family Code (as interpreted under the 1987 Constitution, applicable given the decision date) provides that a marriage contracted by a party psychologically incapacitated to comply with essential marital obligations is void. The controlling doctrinal framework quoted and applied includes the Supreme Court’s clarification that psychological incapacity is a legal—not a strictly medical—concept (Tan-Andal v. Andal), and the evidentiary and doctrinal contours articulated in prior cases (including Republic v. Court of Appeals and Molina and the criminal-context discussion in People v. Madarang).
Factual Findings Established at Trial
The trial record includes testimony that Alfredo was discharged from U.S. Navy service for psychiatric/medical reasons and that he exhibited delusions and religiously framed claims (e.g., believing himself an emissary or son of God, claiming divine orders to leave his wife and to abstain from working, and asserting entitlement to multiple wives). Imputed or actual financial support and benefits were received: Irene acknowledged receiving a United States Veterans Affairs pension apportionment attributable to Alfredo’s disability. Irene also admitted differences in religious beliefs and that she had separated because Alfredo had another woman in his life.
Expert and Documentary Evidence
Alfredo offered expert testimony from clinical psychologist Martha Johanna D. Dela Cruz, who evaluated him and opined that he suffered from schizophrenia, paranoid type, with impaired judgment and a chronic course; she further diagnosed a shared psychotic disorder in Irene based on her written declination of evaluation. The record also includes a medical certificate by Dr. Jose Rommel T. Soriano and written findings from the United States Veterans Affairs Office indicating psychosis-related benefits; the trial court and appellate tribunal relied on these materials together with testimonial corroboration.
Trial Court’s Legal Analysis and Holding
The RTC found that Alfredo had a pre-existing schizophrenic disorder constituting an enduring part of his personality structure, manifested in sustained dysfunction that undermined the marital relationship. The court concluded that Alfredo’s incapacity was grave, had juridical antecedence (existed before marriage), and was incurable in the context of the marriage, thereby satisfying the statutory elements for nullity under Article 36. The RTC declared the marriage null and void, ordered continued child support obligations by Alfredo, and recognized visitation rights.
Appellate and Supreme Court Review Standards Applied
The Supreme Court reiterated that a petition for review on certiorari under Rule 45 raises only questions of law and that findings of fact of the CA are generally binding unless one of the well-established exceptions applies (e.g., findings based on conjecture, manifestly mistaken inferences, grave abuse of discretion, misapprehension of facts, or findings contradicted by the record). The Court found no ground to disturb the lower courts’ factual findings and expert-appreciation conclusions under those exceptions.
Legal Standard for Psychological Incapacity Explained
The Court reiterated that psychological incapacity is a legal concept entailing a durable personality structure that manifests through acts of dysfunctionality preventing compliance with essential marital obligations (Articles 68–71 and related provisions). Three interrelated characteristics—gravity, juridical antecedence, and incurability—must be demonstrated by clear and convincing evidence; however, the condition need not be reducible to a diagnosable medical illness, and a medical label (e.g., schizophrenia) does not automatically equate to legal psychological incapacity.
Application of Law to the Case Facts
Applying the legal standard, the Supreme Court concluded that Alfredo’s psychosis, regardless of its medical label, constituted an enduring personality trait that produced concrete, recurrent dysfunctional acts: refusal to live with his wife and to provide support by virtue of his claimed divine orders; delusions permitting polygamous conduct; hallucinations and commands that undermined mutual love, respect, fidelity, and support; and a long-standing course (decades) without meaningful improvement. The Court held that these facts established the requisite gravity, juridical antecedence, and relative incurability (permanence in relation to this marital relationship), thereby satisfying Article 36’s elements.
Evidentiary Sufficiency and Treatment of Challenges to Evidence
Irene challenged the competence and authentication of certain documents (U.S. Veterans Affairs findings and Dr. Soriano’s certificate) and attempted to minimize the psychiatric evidence. The Supreme Court found that even if some documenta
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Procedural Posture
- Petition for Review on Certiorari filed in the Supreme Court assails the Court of Appeals Decision (September 28, 2012) and Resolution (September 18, 2013) that affirmed the Regional Trial Court (RTC) Decision (September 25, 2007) declaring the parties' marriage null and void due to the respondent's psychological incapacity.
- RTC: Civil Case No. 02-0-2005; Decision penned by Assisting Presiding Judge Consuelo Amog Bocar of the RTC, Olongapo City, Branch 73 (September 25, 2007).
- Court of Appeals: Decision penned by Associate Justice Michael P. Elbinias, concurred by Associate Justices Isaias P. Dicdican and Nina G. Antonio‑Valenzuela (September 28, 2012); Reconsideration denied in Resolution (September 18, 2013).
- Post‑trial motion: Petitioner Irene filed a Motion for New Trial (October 23, 2007) on grounds of collusion, conflict of interest of Alfredo’s counsel, and fraud; RTC denied the Motion (December 27, 2007).
- Supreme Court disposition: Petition for Review on Certiorari denied; Court of Appeals Decision and Resolution affirmed (Judgment per Leonen, J., Sept. 15, 2021; G.R. No. 209278).
Core Facts
- Marriage and family:
- Irene Constantino Datu and Alfredo Fabian Datu married on December 15, 1980 in Subic, Zambales.
- The spouses had two children together.
- Pre‑marriage and discharge from service:
- Alfredo was formerly employed by the United States Navy in 1978.
- After approximately 14 months in service, Alfredo was discharged for medical and psychiatric reasons; psychiatric and medical evaluations reportedly found him suffering from schizophrenia.
- Courtship and marriage circumstances:
- Alfredo and Irene met through friends at the Assembly of God church; became acquainted when Alfredo fetched Irene at her workplace (Shakey’s Pizza, Olongapo City).
- After an incident where they spent a night together at Irene’s boarding house, Irene’s sister insisted they marry, which led to their civil marriage and later a church wedding.
- Marital conduct, separation, and beliefs:
- Alfredo recounted incidents of conflict (e.g., dispute over cooking), accepted apologies “for the sake of religion,” and asserted that Irene did not submit to him as allegedly required by the Book of Ephesians.
- Alfredo testified he believed his utterances come from God, that he was an emissary/son of God, that God ordered him to leave Irene, and that God ordered him not to work. He claimed a premonition that led to his discharge and has refused to work in obedience to this belief.
- Alfredo lived with his maid after leaving Irene and stated he had no plans to remarry.
- Irene’s testimony and admissions:
- Irene formerly worked as a junior supervisor at Shakey’s Pizza and resigned to become a wife and mother.
- Irene admitted she separated from Alfredo because he had “found another woman.”
- She testified to an agreement where Alfredo would give her 60% of his salary as support, but alleged he later failed to comply.
- Irene obtained a $400 benefit from the United States Veterans Affairs Office as Alfredo’s legal wife, used it for daily expenses, and admitted receipt of a pension/apportionment due to Alfredo’s schizophrenia.
- Irene acknowledged differing religious beliefs with Alfredo and that Alfredo believed he could have many wives and that wives should be submissive.
- Irene admitted she did not want the marriage voided because financial support she received might be cut off.
- Third‑party testimony:
- Alfredo’s aunt, Policornia Dela Cruz Fabian, corroborated Alfredo’s discharge for medical and psychiatric reasons, described Irene using Filipino epithets (“inggitera,” “mukhang pera,” “tsismosa”), recounted Irene’s requests for loaned money and rumors about Alfredo’s laziness, and attested that Alfredo recited spiritual messages purportedly from God.
Evidence Adduced
- Documentary and testimonial evidence relied upon by the courts:
- Medical certificate from Dr. Jose Rommel T. Soriano indicating Alfredo was suffering from schizophrenia (admitted in RTC record).
- Written findings by the United States Veterans Affairs Office confirming psychosis (included in the record).
- Expert opinion and psychological evaluation by clinical psychologist Martha Johanna D. Dela Cruz (Dela Cruz), who personally evaluated Alfredo and attempted to evaluate Irene (Irene declined in writing).
- Testimony of Alfredo himself recounting his beliefs, conduct, discharge, and refusal to work.
- Testimony of Policornia corroborating aspects of Alfredo’s mental state and household interactions.
- Irene’s own admissions in court, including receipt of veterans’ benefit because of Alfredo’s schizophrenia and her reluctance to seek nullity for monetary reasons.
- Evidentiary disputes:
- Irene challenged the competency/authentication of the Veterans Affairs findings and Dr. Soriano’s medical certificate and alleged that Dela Cruz’s evaluation merely paraphrased Dr. Soriano.
- The lower courts nonetheless gave credence to the totality of the evidence, including expert testimony.
Expert Testimony and Psychological Findings
- Dela Cruz (clinical psychologist):
- Conducted psychological evaluation of Alfredo in Olongapo City.
- Found Alfredo did not show psychomotor agitation but had impaired judgment.
- Diagnosed psychosis due to schizophrenia, paranoid type.
- Testified that Alfredo’s schizophrenia had no cure, that he was under medication, and was still suffering from schizophrenia at the time of testimony.
- Analyzed Irene’s written declination for evaluation and concluded Irene suffered from shared psychotic disorder; opined that the spouses could not live together or both would become suicidal.
- Medical certification and VA findings:
- Dr. Soriano’s medical certificate and written findings of the United States Veterans Affairs Office corroborated the diagnosis of psychosis/schizophrenia and the reason for Alfredo’s discharge.
- Lay corroboration:
- Policornia’s testimony corroborated Alfredo’s psychiatric history and his spiritual utterances.
Trial Court Findings and Rationale
- RTC’s principal factual determinations:
- Plaintiff (Alfredo) sufficiently proved he suffered from schizophrenia (paranoid type) even before marrying Irene.
- Multiple expert opinions and documentary/testimonial evidence showed Alfredo’s discharge from the U.S. Navy was due to the me