Case Summary (G.R. No. L-17314)
Background and Proceedings
The case involves a Petition for Review on Certiorari filed by Gerardo A. Eliscupidez seeking to overturn the Court of Appeals’ decision that reversed the Regional Trial Court's (RTC) ruling, which declared the marriage between the petitioner and the respondent void ab initio due to the respondent’s psychological incapacity. Petitioner and respondent were married on November 20, 1990, after a tumultuous courtship beginning in 1986. The marriage produced two children. The petition to declare the marriage null was filed on March 13, 2012, citing psychological incapacity as the basis for nullity.
Factual Background
Petitioner alleged that the respondent exhibited numerous troubling behaviors during their marriage, including frequent violent outbursts, infidelity, and neglect of marital responsibilities. Evidence was gathered through testimonies, including that of a household help, which highlighted the turbulent nature of their relationship and the respondent's erratic behaviors. The petitioner also presented a Psychological Evaluation Report by psychologist Dr. Nedy L. Tayag, who concluded that the respondent's psychological incapacity was characterized by a disorder that existed before the marriage, deemed grave and permanent.
Lower Court Rulings
The RTC ruled in favor of the petitioner, declaring the marriage void based on the psychological incapacity of the respondent. The Office of the Solicitor General (OSG) contested this decision, arguing that the evidence was inadequate to prove psychological incapacity. The Court of Appeals subsequently found merit in the OSG's appeal, stating that the negative traits displayed by the respondent did not meet the legal standards for psychological incapacity as defined in relevant jurisprudence.
Court of Appeals' Findings
The Court of Appeals determined that the evidence presented by the petitioner did not sufficiently establish that the respondent was psychologically incapacitated at the time of their marriage. The appellate court criticized the reliance on Dr. Tayag’s report, stating that it lacked depth and did not conclusively demonstrate that the respondent's psychological issues were deeply rooted and incurable.
Legal Standards for Psychological Incapacity
The Supreme Court reiterated that for a marriage to be annulled based on psychological incapacity, the petitioner must demonstrate (a) gravity, (b) juridical antecedence, and (c) incurability of a diagnosed psychological condition. The incapacity must be significant enough to hinder the individual from fulfilling marital responsibilities. The court emphasized that such psychological disorders must be clinically identified and supported by substantive evidence to warrant a declaration of nullity.
Supreme Court Decision
The Supreme Court denied the petition of the petitioner, affirming the Court of Appeals. The Court determined that the evidence presented was no
...continue readingCase Syllabus (G.R. No. L-17314)
Case Background
- This case involves a Petition for Review on Certiorari under Rule 45, filed by Gerardo A. Eliscupidez (Petitioner) seeking to reverse a decision from the Court of Appeals (CA) dated May 31, 2016.
- The CA decision set aside the Regional Trial Court (RTC) ruling that declared the marriage between Petitioner and Glenda C. Eliscupidez (Respondent) void ab initio on the grounds of psychological incapacity.
- The marriage took place on November 20, 1990, after a prolonged "on-and-off" relationship since 1986, resulting in two children.
Procedural History
- On March 13, 2012, Petitioner filed a Petition for Declaration of Nullity of Marriage under Article 36 of the Family Code.
- Petitioner faced difficulties in serving summons to Respondent, leading to the RTC allowing service by publication.
- An investigation by the public prosecutor found no collusion between the parties.
- The RTC trial included testimonies from Petitioner, their household helper Irene V. Oro, and a psychological evaluation report from Dr. Nedy L. Tayag.
Evidence Presented
- Petitioner described a tumultuous relationship characterized by frequent fights, jealousy, and control from Respondent.
- Testimonies included instances of physical violence, including an incident where Respondent allegedly attacked Petitioner with a knife.
- Evidence of Respondent's attempts to avoid pregnancy through abortifacient medicines was presented, alongside claims of her engaging in extramarital affairs.
- Dr. Tayag’s psychological evaluation indicated Respondent exhibited traits of histrionic personality disorder and antisocial personality traits, concluding that her psychological inca