Case Summary (G.R. No. 134431)
Key Dates and Procedural Posture
Trial court decision: Regional Trial Court (Makati City), June 5, 2017 — declared the marriage void ab initio for Rowena’s psychological incapacity. Court of Appeals: affirmed in a decision dated June 30, 2020 and denied reconsideration on January 29, 2021. Supreme Court disposition: petition for review on certiorari denied (final affirmance). The decision under review arises after 1990 and therefore is governed by the 1987 Constitution.
Applicable Law and Governing Legal Standards
Governing provision: Article 36, Family Code (psychological incapacity as ground for annulment). Constitutional backdrop: the 1987 Constitution’s protection of marriage and family underpins the presumption of validity and the high standard for declaring marriages void. Controlling jurisprudential principles applied include (as articulated in the decision): Santos v. Court of Appeals (definition of psychological incapacity); Molina (original guidelines); the refinement and abandonment in part of Molina by Tan‑Andal v. Andal (not requiring medical/clinical identification of a disorder; focusing on durable personality structure and legal/functional incurability); and later applications in Georfo and Datu clarifying evidentiary approaches, the role of expert opinion, and the emphasis on clear and convincing evidence. The three characteristic requirements remain: gravity, juridical antecedence, and incurability (the latter understood in a legal, not purely medical, sense). The required quantum of proof is clear and convincing evidence.
Evidence Adduced at Trial
Primary expert evidence: Psychiatric Evaluation Report by Dr. Ma. Bernadette Manalo‑Arcena, based on clinical tests and interviews with Jeffery, Rowena, Rowena’s mother, and a mutual friend. Documentary and demonstrative evidence: DNA test result concerning Abigail’s paternity, photographs showing intimate conduct with another man, collection and civil actions for unpaid debts and loans, alleged falsified Transfer Certificate of Title, and records of civil and criminal cases. Procedural facts relevant to evidentiary weight: Rowena was served but did not file an answer nor participate in pretrial; the Office of the City Prosecutor reported no collusion between parties.
Trial Court Findings of Fact and Conclusion
The trial court declined to find psychological incapacity on Jeffery’s part but accepted the psychiatric diagnosis that Rowena exhibited a personality structure consistent with Borderline Personality Disorder and Antisocial Personality Disorder (characterized in the decision as Personality Disorders Not Otherwise Specified). The court summarized manifestations: frantic efforts to avoid abandonment; unstable relationships and self‑image; impulsivity; affective instability; difficulty controlling anger; repeated deceitfulness and fraud; compulsive gambling; consistent irresponsibility in meeting financial obligations; lack of remorse; and repeated acts contrary to social/legal norms. The court found these traits rooted in antecedent trust problems and poor parental models dating to adolescence, and legally incurable insofar as they rendered Rowena unable to assume and discharge essential marital obligations (living together, love, respect, fidelity and support). Accordingly, the trial court declared the marriage void ab initio under Article 36.
Court of Appeals Rationale
The Court of Appeals affirmed the trial court. It held that the totality of evidence established that Rowena had a psychological impairment at the time of marriage that prevented and would continue to prevent her from performing essential marital obligations. The CA relied on the psychiatric evaluation supported by documentary proof of deception, debts, fraud (alleged spurious title), the DNA result, photographic evidence of an extramarital relationship, and the pattern of litigation and financial irresponsibility. The CA expressly found that the elements of gravity, juridical antecedence, and incurability were satisfied and that the petitioner (Jeffery) met the burden of proof by clear and convincing evidence.
Supreme Court Analysis and Application of Legal Standards
Standard applied: the Court reaffirmed that Article 36 claims must be judged case‑by‑case under the framework refined by Tan‑Andal and subsequent cases: psychological incapacity requires proof of a durable personality structure manifested in acts of dysfunctionality that effectively prevent understanding and complying with essential marital obligations; proof must be clear and convincing; expert evidence is not strictly required but may be considered. Credibility and probative weight: the Supreme Court gave probative value to Dr. Manalo‑Arcena’s psychiatric evaluation because it was based on standard testing and multiple sources (interviews of the spouse, the spouse’s mother, and a mutual friend), reducing the risk of unilateral bias. The Court relied on Georfo’s reasoning that psychological assessments derived from sources other than the petitioner may be accorded credibility unless there is reason to believe supporting testimonies are fabricated. The Court found no persuasive reason to discount the expert evaluation as unreliable or improperly grounded.
Addressing petitioner’s objections: Rowena argued that (1) the psychologist’s recounting of statements by Rowena’s mother constituted unreliable hearsay, (2) the expert lacked sufficient reliable information to reach a diagnosis, (3) debts alone cannot constitute psychological incapacity, (4) there was no proof of infidelity and Jeffery knew Abigail was not his child yet acknowledged her, and (5) separate households and Rowena’s claimed compartmentalization did not show incapacity. The Court rejected these contentions on the basis that the psychiatric evaluation relied on multiple corroborating factual matrices (documents, photos, DNA, litigation records, testimony), that the character and pattern of Rowena’s conduct (deception, gambling, fraud, continued extramarital relationships, financial irresponsibility, refusal to cohabit) constituted clear acts of dysfunctionality undermining marital obligations, and that the origin of these traits predated marriage (juridical antecedence). The Court also reiterated that incurability is to be assessed legally — whether the personality structure would persist and render the marriage inevitably unsustainable — and found that to be the case here.
Findings as to the
...continue readingCase Syllabus (G.R. No. 134431)
Procedural Posture and Relief Sought
- Petition for Review on Certiorari filed by Rowena Manlutac-Green (petitioner) assails: (a) June 30, 2020 Decision and (b) January 29, 2021 Resolution of the Court of Appeals, which affirmed the June 5, 2017 Decision of the Regional Trial Court (RTC), Branch 140, Makati City.
- Subject matter: RTC declared the marriage between Rowena and Jeffery A. Green void ab initio on the ground of petitioner’s psychological incapacity under Article 36 of the Family Code.
- Relief sought by petitioner: reversal of Court of Appeals’ affirmation and preservation of the marriage; challenge to factual findings and weight given to expert testimony.
- Respondents: Jeffery A. Green (petitioner-appellee below) and the Republic of the Philippines (Office of the Solicitor General, with the Office of the City Prosecutor of Makati City authorized to appear on its behalf).
- Supreme Court disposition: Petition denied; Court of Appeals’ June 30, 2020 Decision and January 29, 2021 Resolution affirmed.
Relevant Chronology of Key Events
- Circa 2006: Jeffery, United States Navy retiree, met Rowena in a bar owned by her mother in Angeles City, Pampanga; friendship developed into steady dating.
- August 22, 2008: Rowena gave birth to daughter Abigail; Jeffery acknowledged paternity at the time.
- May 8, 2010: Jeffery and Rowena married at St. Ignatius de Loyola Cathedral in Quezon City.
- Post-marriage living arrangement: Jeffery worked and stayed in Makati City; Rowena stayed with him three to four days a week and returned to her children in Angeles City for the remaining days.
- July 7, 2014: Jeffery filed a Petition for Declaration of Nullity of Marriage on basis of both parties’ psychological incapacity under Article 36.
- November 29, 2014: Rowena duly served with summons but did not file an answer.
- June 16, 2015: Pre-trial conference terminated without petitioner filing pre-trial brief.
- June 5, 2017: RTC rendered decision declaring the marriage null and void ab initio for Rowena’s psychological incapacity.
- August 11, 2017: RTC denied Rowena’s Motion for Reconsideration.
- Court of Appeals: June 30, 2020 Decision affirmed RTC; January 29, 2021 Resolution denied reconsid. of Rowena.
- Supreme Court: Decision rendered February 17, 2025 (G.R. No. 255706) denying the petition.
Evidence Presented at Trial
- Psychiatric Evaluation Report authored by Dr. Ma. Bernadette Manalo-Arcena (Dr. Manalo-Arcena), based on interviews with: Jeffery, Rowena, Rowena’s mother, and the spouses’ mutual friend; and conduct of standard psychological tests.
- Documentary evidence submitted by Jeffery:
- Copies of collection cases filed against petitioner (evidence of debts and financial delinquencies).
- DNA test result showing that Jeffery Green is not the biological father of Abigail (contrary to prior belief/acknowledgement).
- Photographs depicting petitioner hugging and holding hands with another man (allegation of infidelity).
- Allegedly spurious Transfer Certificate of Title No. 90148 and other evidence relating to a house in Angeles City.
- Allegations and documentary indicia of numerous debts totalling approximately PHP 4 million (as summarized in Psychiatric Evaluation Report).
- Additional factual allegations and documentary support attached to the petition: petitioner’s alleged infidelity, lies, debts, gambling, falsification of documents, and civil and criminal cases stemming from financial dealings.
- Record of service and procedural filings: summons, Office of the Solicitor General’s appearance and manifestations, Office of the City Prosecutor’s manifestation finding no collusion.
Dr. Manalo-Arcena’s Psychiatric Evaluation — Methodology and Findings
- Methodology:
- Conducted interviews with declared sources: Jeffery, Rowena, Rowena’s mother, and the spouses’ mutual friend.
- Administered a series of standard tests (the report was offered in evidence).
- Diagnostic conclusions:
- Identified a personality structure characterized as Borderline Personality Disorder and Antisocial Personality Disorder, falling into the category of Personality Disorders Not Otherwise Specified.
- Characteristic manifestations attributed to Borderline Personality Disorder (as listed by Dr. Manalo-Arcena and adopted by trial court):
- Frantic efforts to avoid real or imagined abandonment.
- Unstable relationships (with petitioner’s mother and with Jeffery).
- Unstable self-image.
- Impulsivity.
- Affective instability.
- Difficulty in controlling anger.
- Characteristic manifestations attributed to Antisocial Personality Disorder (as listed):
- Failure to conform to social norms with respect to lawful behaviors (repeated acts that are grounds for arrest).
- Deceitfulness (repeated lying, use of aliases, conning others for personal profit or pleasure).
- Impulsivity or failure to plan ahead.
- Irritability and aggressiveness (repeated physical fights or assaults).
- Reckless disregard for the safety of self or others.
- Consistent irresponsibility (repeated failure to sustain consistent work behavior or honor financial obligations).
- Lack of remorse (indifference to or rationalization of having hurt, mistreated, or stolen from another).
- Attributed root cause and permanence:
- Personality structure traced to problems of trust from early age (around 15) and poor parental model figures.
- Dr. Manalo-Arcena found the personality structure continuing and incurable in the relevant legal sense, manifested by the absence of obligations to live together, give love, respect, loyalty, fidelity, and support within the marriage.
Trial Court’s (RTC) Findings and Rationale
- RTC conclusions:
- Insufficient evidence to show Jeffery’s psychological incapacity.
- Sufficient evidence to establish Rowena’s psychological incapacity (Borderline Personality Disorder and Antisocial Personality Disorder — Personality Disorders Not Otherwise Specified).
- RTC’s consideration of Dr. Manalo-Arcena’s report:
- Accepted the psychiatrist’s description of traits and manifestations.
- Adopted the trial court’s findings enumerating Rowena’s deceit, impulsivity, debts, gambling, falsification of title, lying about paternity, extramarital affairs, and multiple civil/criminal cases as indicia of failure to conform to social norms and incapacity to assume marital obligations.
- RTC ordered cancellation of marriage registration in local Books of Marriages and directed furnishing of copies of the decision to relevant registration and prosecutorial authorities.
Court of Appeals’ Decision and Rationale
- Court of Appeals affirmed RTC’s June 5, 2017 Decision in its June 30, 2020 Decision.
- Key appellate findings:
- Jeffery overcame the burden of proving petitioner Rowena’s psychological incapacity.
- Rowena, at the time of marriage,