Case Summary (G.R. No. 179230)
Background of the Case
The couple had three children during their marriage: Lester Edward, Candice Grace, and Mariano III. They initially lived with petitioner’s family in Forbes Park, Makati City. Despite their relatively comfortable living situation, tensions arose due to respondent's desire for independence from her husband's family. Significant marital upheaval occurred on October 14, 1990, when respondent reported an incident involving petitioner and a caregiver, causing public embarrassment and leading to her eventual departure from the marital home with their children.
Initial Legal Actions
Following her departure, respondent filed various legal complaints against petitioner, including allegations of concubinage and physical injuries. Although these complaints were dismissed due to lack of merit, she subsequently sought spousal support, resulting in a court order for petitioner to provide financial support for their children. On October 29, 1999, Edward Lim petitioned for a declaration of nullity of marriage based on psychological incapacity under Article 36 of the Family Code.
Findings by the Regional Trial Court
In July 2002, an amended petition was filed, including allegations of both parties’ psychological incapacity, as both had been diagnosed with personality disorders—dependent personality disorder for Edward and histrionic personality disorder for Cheryl. The trial court, led by Judge Leticia P. Morales, found sufficient grounds for annulment based on a Psychiatric Report submitted by Dr. Cecilia C. Villegas, confirming that both parties were psychologically incapacitated. The RTC ruled the marriage void ab initio, asserting the necessity of legal recognition of this condition.
Appeal to the Court of Appeals
Dissatisfied with the RTC’s decision, the Office of the Solicitor General appealed to the Court of Appeals (CA), contesting the finding of psychological incapacity. The CA ultimately reversed the RTC’s decision, declaring the marriage valid and subsisting, citing the inadequacy of the evidence presented to substantiate claims of psychological incapacity.
Supreme Court Review
Edward Lim, in seeking further recourse, filed a petition for review on certiorari with the Supreme Court. The sole issue determined was whether the marriage was null and void due to psychological incapacity. The Supreme Court referenced the precedents set in Santos v. Court of Appeals, which outlined the defining criteria for psychological incapacity as being grave, rooted in prior history before marriage, and incurable.
Requirements for Psychological Incapacity
The Supreme Court emphasized that the burden was on the petitioner to demonstrate both parties' psychological incapacity meeting the stringent criteria. Among the requirements were clear evidence connecting the diagnosed disorders to the inability to fulfill marital obligations and the permanence of these conditions.
Evaluation of Expert Testimony
The Court scrutinized the testimony of Dr. Villegas, noting that while she diagnosed both parties with per
...continue readingCase Syllabus (G.R. No. 179230)
Case Overview
- This case involves a petition for the declaration of nullity of marriage based on psychological incapacity under Article 36 of the Family Code.
- Petitioner Edward N. Lim contends that both he and his wife, respondent Ma. Cheryl Sta. Cruz-Lim, suffer from psychological disorders that prevent them from fulfilling essential marital obligations.
- The petition follows a tumultuous marriage that began in December 1979 and ended in October 1990 when the respondent left the petitioner, taking their three children.
Background of the Parties
- Edward N. Lim, aged 26 at the time of marriage, was a college student and worked in a family business. He grew up in a household with strong Chinese traditions, living communally with his extended family.
- Ma. Cheryl Sta. Cruz-Lim, a secretarial student, became Edward's sweetheart in early 1979 after a year of long-distance courtship.
- The couple married at the Don Bosco Church in Makati City, living initially with Edward's grandparents and parents in Forbes Park, Makati City.
Events Leading to the Petition
- Tensions arose in the marriage, particularly due to the couple's living arrangements and Edward's infidelity, which was publicly exposed, causing humiliation to both parties.
- Respondent left the family home after filing a police complaint against Edward for concubinage and physical injuries, which was dismissed for lack of merit.
- A subsequent court ruling required Edward to provide monthly support for their