Case Summary (G.R. No. 162318)
Factual Antecedents
Hannamer and Grant, initially high school classmates who became romantically involved, married on March 12, 2003, after Hannamer became pregnant. Their marriage was financed by Hannamer, as Grant was unemployed and financially dependent on his family. The couple's relationship deteriorated after Hannamer's mother moved in with them, leading to severe marital discord. By January 3, 2010, Hannamer filed a petition for declaration of nullity of marriage, claiming that Grant was psychologically incapacitated and unable to fulfill his marital duties.
Initial Proceedings
The RTC issued summons to Grant through his uncle; however, he did not attend the subsequent hearings. The Assistant Provincial Prosecutor indicated her intent to ensure the authenticity of the proceedings despite Grant’s absence. During trial, Dr. Visitacion Revita testified about Grant's psychological evaluation, diagnosing him with narcissistic personality disorder, which rendered him incapable of fulfilling his obligations as a husband and father. Dr. Revita opined that his condition was rooted in his upbringing and family environment.
Ruling of the Regional Trial Court
On June 29, 2011, the RTC granted Hannamer's petition, declaring the marriage void ab initio based on Grant's psychological incapacity under Article 36 of the Family Code. The court ordered the cancellation of the marriage records and granted custody of the child to Hannamer.
Appeal to the Court of Appeals
The Office of the Solicitor General, representing the Republic, appealed the RTC’s ruling, arguing that Hannamer did not adequately prove Grant's psychological incapacity, suggesting that his actions did not equate to a complete inability to fulfill marital obligations. The OSG emphasized that expert testimony must be based on direct examination rather than hearsay.
Ruling of the Court of Appeals
The CA reversed the RTC’s decision on March 31, 2014, asserting that Hannamer failed to demonstrate that Grant's marital shortcomings stemmed from an incurable psychological illness existing at the time of marriage. It determined that the psychological findings were based on hearsay and lacked sufficient foundation to support the claim of psychological incapacity, rendering the marriage valid and subsisting.
Analysis of Psychological Incapacity Standards
To establish nullity under Article 36 of the Family Code, psychological incapacity must be (1) grave; (2) characterized by juridical antecedence, meaning it existed prior to the marriage; and (3) incurable. While it was noted that expert testimony is significant in such cases, it is not strictly mandatory if the evidence sufficiently supports the claim.
Consideration of Relevant Case Law
The ruling referenced the guidelines set forth in Molina and noted the shift in interpretation represented in Tan-Andal v. Andal. The Tan-Andal framework relaxed the stringent requirements associated wi
...continue readingCase Syllabus (G.R. No. 162318)
Case Overview
- This case involves a petition for review on certiorari filed by Hannamer C. Pugoy-Solidum against the Republic of the Philippines, challenging the decisions of the Court of Appeals (CA) which reversed the Regional Trial Court's (RTC) ruling granting the petition for nullity of her marriage to Grant C. Solidum.
- The petition was decided by the Second Division of the Supreme Court on April 20, 2022.
Factual Antecedents
- Hannamer and Grant were high school classmates and later became romantically involved.
- After graduation, they cohabited, and Hannamer became the primary financial provider for Grant and his family until she became pregnant and had to stop working.
- Their marriage was solemnized on March 12, 2003, by Judge Albert S. Abragan in Iligan City. Hannamer financed their wedding and the baptism of their child.
- Financial difficulties arose, causing strain in their relationship, exacerbated by Grant's gambling habits and lack of employment.
- Following a series of conflicts, Hannamer left their home and eventually lost contact with Grant.
- On January 3, 2010, Hannamer petitioned for nullity of marriage, citing Grant's psychological incapacity to fulfill marital obligations under Article 36 of the Family Code.
Proceedings in the Regional Trial Court
- The RTC of Tagaytay City served summons to Grant through his uncle, but he failed to appear at the hearing.
- Hannamer testified about Grant's behaviors and responsibilities, supported by a psychological report from Dr. Visitacion Revita, who diagnosed Grant with narcissistic personality disorder.
- Dr. Re