Case Summary (G.R. No. 212971)
Facts of the Case
John Arnel H. Amata and Haydee N. Amata were married and had three children together. Initially, their marriage was harmonious but later became strained due to issues such as Haydee's allegedly domineering behavior and dissatisfaction in their sexual relationship. The situation worsened, leading the respondent to consult a clinical psychologist. The psychologist diagnosed the respondent with Passive-Aggressive Personality Disorder, attributing his psychological incapacity to his marriage obligations. The respondent subsequently filed a petition for nullity, citing this diagnosis.
Proceedings Before the Regional Trial Court
The Regional Trial Court (RTC) ruled on July 20, 2011, that the marriage was void ab initio, asserting that the respondent's psychological incapacity prevented him from fulfilling marital duties. Haydee's claims—seeking reconciliation and denying the allegations of incapacity—were not persuasive to the court. This ruling prompted the Office of the Solicitor General to appeal to the Court of Appeals, while Haydee sought reconsideration.
Ruling of the Court of Appeals
On May 29, 2014, the Court of Appeals upheld the RTC's ruling, affirming that sufficient evidence of psychological incapacity, as assessed by the psychologist, warranted the declaration of nullity of marriage. The petitioner argued, however, that the evidence was insufficient to support such a conclusion.
Main Issue
The principal legal issue presented is whether there exists sufficient basis to declare the respondent's marriage void on the ground of psychological incapacity in accordance with Article 36 of the Family Code.
Preparation for Review
In addressing the procedural matters, the Supreme Court recognized that the motion for an extension to file a petition for review was valid under the Rules of Court, allowing an appeal from the OSG, which argued that the lower courts had erred in their rulings regarding psychological incapacity.
Relevant Legal Principles
Article 36 of the Family Code stipulates that a marriage contracted by a party who is psychologically incapacitated to fulfill the essential marital obligations at the time of the celebration is void. The characteristics of psychological incapacity include its gravity, juridical antecedence (i.e., it must predate the marriage), and incurability.
Judicial Analysis
The Supreme Court evaluated the evidence to determine if it substantiated the respondent's assertion of psychological incapacity. The Court observed that merely exhibiting difficulties or dissatisfaction in marital life does not equate to psychological incapacity. Significant focus was placed on whether the respondent’s alleged condition was serious, chronic, and sufficiently debilitating to prevent him from executing his marital obligations.
Findings of the Supreme Court
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Case Overview
- The case is an appeal arising from a Petition for Review on Certiorari challenging the May 29, 2014 Decision of the Court of Appeals (CA), which upheld the July 20, 2011 Decision of the Regional Trial Court (RTC) of Imus, Cavite.
- The RTC had declared the marriage of John Arnel H. Amata (respondent) and Haydee N. Amata (Haydee) void ab initio based on Article 36 of the Family Code, citing psychological incapacity.
Background Facts
- John Arnel H. Amata and Haydee N. Amata met at the Pamantasan ng Lungsod ng Maynila and eventually married, having three children.
- The marriage initially was harmonious but later became tumultuous due to Haydee's domineering behavior and dissatisfaction with their sexual relationship.
- Tensions escalated when John attended a workshop in Iloilo City, where he developed feelings for another woman, leading to Haydee's suspicions and subsequent accusations of infidelity.
- John sought psychological evaluation and consulted Dr. Elena A. Del Rosario, who diagnosed him with Passive-Aggressive Personality Disorder and recommended annulment based on psychological incapacity.
Trial Court Proceedings
- Haydee contested the petition, arguing that it lacked specific allegations of incapacity and expressed her willingness to reconcile.
- The RTC ruled in favor of John, declaring the marriage void ab initio based on credible