Title
Dela Cruz-Lanuza vs. Lanuza
Case
G.R. No. 242362
Decision Date
Apr 17, 2024
The Supreme Court declared the marriage of Leonora and Alfredo void due to Alfredo's psychological incapacity to fulfill marital obligations, stemming from long-term neglect and infidelity.

Case Summary (G.R. No. 242362)

Petitioner’s Core Claims and Factual Background

Leonora alleged that she and Alfredo were married on June 9, 1984 but that no marriage license was actually obtained nor did she appear before the Local Civil Registrar of Imus, Cavite. She asserted that Alfredo later became psychologically incapacitated: he came home late or not at all, failed to provide financial support, treated her without spousal regard, engaged in extramarital affairs, and separated from the family in 1994. Leonora also alleged Alfredo contracted subsequent marriages in 1994 and 2000 and attached a PSA certification listing three marriage records bearing variants of Alfredo’s name.

Evidence Presented at Trial

Leonora testified about the marriage, separation in 1994, lack of financial support, and minimal contact (one brief school visit in 1999). She presented Clinical Psychologist Noel N. Ison as an expert witness. Ison conducted a clinical interview of Leonora and collateral interviews of Leonora’s sister and one daughter; he did not examine Alfredo personally because Alfredo did not respond to invitations. Based on available collateral information and psychological testing of Leonora, Ison concluded Alfredo suffered from Narcissistic Personality Disorder with borderline personality traits and opined this disorder had juridical antecedence, was grave and permanent relative to Leonora, and incapacitated him from performing essential marital obligations.

RTC Decision and Reasoning

The RTC (Decision dated December 27, 2017) denied Leonora’s petition. The court found insufficient proof of the alleged subsequent marriages because Leonora did not submit the corresponding marriage certificates. The RTC held that, even assuming the subsequent marriages occurred, infidelity alone is not sufficient to prove psychological incapacity under Article 36 of the Family Code; there must be other circumstances showing durable, aberrant attitudes and behavioral patterns constituting a personality structure that pre-existed or existed at the time of marriage. The RTC also questioned Ison’s report for lack of particulars and specific factual bases tying his generalized descriptions to Alfredo’s concrete acts and circumstances; it further noted Leonora’s own testimony that Alfredo had initially been “very kind, gentle and witty,” which undermined the claim of pre-existing incapacity.

Court of Appeals’ Procedural Rulings

Leonora filed a Petition for Review under Rule 42 with the Court of Appeals. The CA dismissed that petition as the wrong remedy (May 31, 2018 Resolution) because the RTC rendered judgment in the exercise of original jurisdiction and the proper mode of appeal was an ordinary appeal under Rule 41(a) or, if purely questions of law were involved, a petition for review on certiorari under Rule 45. The CA denied reconsideration (October 2, 2018), emphasizing the statutory nature of the right to appeal and the jurisdictional consequence of failing to perfect the correct remedy.

Issues Framed for the Supreme Court

The Supreme Court identified two issues: (1) whether the Court of Appeals erred in dismissing the appeal on procedural grounds, and (2) whether the totality of evidence supported a declaration that the marriage was void for psychological incapacity under Article 36 of the Family Code.

Procedural Holding of the Supreme Court

Applying the 1997 Rules of Civil Procedure (appeal filed in 2018, prior to the 2019 Rules), the Supreme Court agreed that the CA did not err in concluding that Rule 42 was the wrong remedy for an RTC decision rendered in original jurisdiction; the appropriate avenue would have been Rule 41(a) or Rule 45 as applicable. Nevertheless, invoking the Court’s discretion to relax rules in appropriate circumstances (citing the Malixi factors), the Supreme Court determined the substantive case was meritorious and therefore gave due course to the petition despite the procedural infirmity.

Substantive Standard for Psychological Incapacity

The Court reiterated controlling doctrine from Tan-Andal and subsequent cases: psychological incapacity under Article 36 is a legal concept concerning a durable aspect of personality structure that manifests in clear acts of dysfunctionality undermining the family and making it impossible for the spouse to understand and comply with essential marital obligations. Requirements include: (a) proof by clear and convincing evidence; (b) manifestation of enduring personality traits (personality structure) producing dysfunction; (c) juridical antecedence or existence of the incapacity at the time of marriage; and (d) the incapacity must be grave and attributable to a genuine psychic cause. Expert opinion may be persuasive but is not indispensable; ordinary witnesses may testify about consistent behaviors observed before marriage. Collateral psychiatric information is an accepted practice when direct examination is not available.

Application of Law to Facts and Supreme Court’s Findings

Considering the totality of evidence, the Supreme Court found that Leonora established Alfredo’s psychological incapacity. The Court emphasized these factual indicators: long unjustified absence from the family after 1994; al

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