Case Summary (G.R. No. 189999)
Applicable Law
The case examines the principles outlined in the 1987 Philippine Constitution, particularly in relation to psychological incapacity under Article 36 of the Family Code.
Marriage License and Claims of Psychological Incapacity
Leonora asserted that they married without securing a marriage license, which she contended was a legal prerequisite for a valid marriage. She recounted their initially harmonious relationship, which later deteriorated as Alfredo exhibited behaviors consistent with psychological incapacity, such as neglect, infidelity, and prolonged absences from the marital home.
Breakdown of the Marriage
Evidence presented included testimony about Alfredo's late-night outings, failure to provide for the family, and an illicit affair that led to their separation in 1994. Additionally, it was revealed that Alfredo subsequently remarried multiple times, further complicating the marital status.
Psychiatric Evaluation
To substantiate her claims, Leonora underwent a psychological evaluation, conducted by Clinical Psychologist Noel N. Ison, who diagnosed Alfredo with narcissistic personality disorder and indicated that such conditions may render an individual unable to fulfill marital obligations. Importantly, Ison relied on the testimonies of Leonora and her family, as Alfredo declined to cooperate with the evaluation process.
Regional Trial Court's Decision
The Regional Trial Court (RTC) denied Leonora’s petition, reasoning that there was insufficient evidence to substantiate Alfredo's psychological incapacity or the legitimacy of his subsequent marriages. The RTC ruled that proof of infidelity alone does not establish psychological incapacity and pointed out the lack of specific findings by Ison correlating Alfredo's purported disorders with his inability to comply with marital obligations.
Appellate Review and Procedural Grounds
Following the RTC's decision, Leonora sought a Petition for Review with the Court of Appeals, which dismissed her appeal due to procedural improprieties under Rule 42 of the Rules of Court. The appellate court expressed that Leonora's appeal should have instead utilized an ordinary appeal mechanism under Rule 41, emphasizing that procedural errors can impair jurisdiction.
Supreme Court Review
Leonora challenged the Court of Appeals' decision on grounds of grave abuse of discretion. The Supreme Court evaluated the merits and the procedural aspects of her petition. It concluded that the appeal had merit notwithstanding the procedural error cited by the Court of Appeals, as the substantive issues raised regarding Alfredo's psychological incapacity warranted further examination.
Nullity of Marriage and Psychological Incapacity
In reviewing psychological incapacity as a legal concept, the Supreme Court reiterated that evidence of persistent dysfunctional behavior indicative of incapacity must exist to declare a marriage void. The Court undersco
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Factual Background
- Leonora O. Dela Cruz-Lanuza (petitioner) and Alfredo M. Lanuza, Jr. (respondent) were married in June 1984, with four children born of the marriage.
- Although the marriage contract states a marriage license was secured from Imus, Cavite, Leonora testified no such license was ever applied for or secured.
- Alfredo exhibited changing behaviors post-marriage, including coming home late or early morning, neglecting family duties, failing to provide financially, and treating Leonora as merely a house occupant.
- Alfredo engaged in illicit affairs, leading to separation in 1994.
- Alfredo married two other women subsequent to the first marriage: Mary Ann Makalintal in 1994 and Jane Alejo in 2000.
- Leonora filed a bigamy complaint against Alfredo, which was later archived because Alfredo could not be located.
- Alfredo was dismissed from police service after going AWOL linked to the bigamy case.
- Alfredo’s abandonment of the family and lack of financial support were established, including minimal visitation to his children.
Legal Proceedings
- Petitioner filed a Petition for Declaration of Nullity of Marriage before the Regional Trial Court (RTC) of Caloocan City on grounds of lack of valid marriage license and psychological incapacity.
- During trial, expert witness Clinical Psychologist Noel N. Ison was presented; he evaluated Leonora and family members but not Alfredo due to non-cooperation.
- Ison concluded Alfredo suffered from narcissistic personality disorder with borderline personality traits causing psychological incapacity.
- The RTC, in a December 2017 Decision, denied the petition citing insufficient proof of Alfredo’s subsequent marriages and questioned the sufficiency and specificity of Ison’s findings.
- Motion for reconsideration by Leonora was denied by the RTC in April 2018.
- Leonora’s appeal to the Court of Appeals (CA) was dismissed on procedural grounds: she filed a Petition for Review under Rule 42 instead of a Notice of Appeal, the correct remedy for RTC decisions in original jurisdiction.
- Motion for reconsideration to CA was also denied.
- Leonora elevated the case to the Supreme Court via Petition for Review on Certiorari claiming grave abuse of discretion by CA and RTC.
Issues Presented
- Whether the Court of Appeals erred by dismissing the case on procedural grounds.
- Whether the totality of evidence establishes psychological incapacity sufficient to annul the m